VoIP and 911

I think I lose my Telecom Blogger Card if I don't write something about the FCC's VoIP E911 order. So some observations.

First, basing any conclusions on the FCC's press release, instead of the Report and Order that isn't available yet, is risky. The language is imprecise, the requirements are fuzzy, and the obligations are unclear.

That said...

The FCC's determination of who it's placing obligations on seems broad. "Interconnected VoIP service providers," that have obligations placed on them, are defined as those who "enable customers to receive calls from and terminate calls to the public switched telephone network." By that definition, Skype (for example) could be considered an "Interconnected VoIP service provider", as Skype (the company that offers the SkypeIn and SkypeOut services) enables customers to receive calls from and terminate calls to the public switched telephone network. The definition of "Interconnected VoIP service providers" says nothing about how the provider markets the service, or whether there's an ATA supporting 2500 sets - all it says is "enable customers to receive calls from and terminate calls to the public switched telephone network."

The consistent use of the term "interconnected VoIP provider" to describe who the FCC is placing obligations on, but a change to the term "telecommunications carrier" to describe who the ILECs are obligated to provide E911 access to, is worrisome. While I suspect that the overwhelming majority of VoIP providers make use of a CLEC or a third-party provider such as Intrado to provide E911 interconnection, this apparent limitation of the obligations of the ILECs to their current "statutory obligation to provide requesting telecommunications carriers access to their 911 network" makes Chairman Martin's statement that "VoIP providers may interconnect directly with the incumbent LECs’ 911 network or purchase access to this network from competitive carriers and other third-party providers" sound somewhat disingenuous.

Finally, the Commission doesn't seem to have thought through the implications of "nomadic VoIP" - taking one's ATA (or using one's softphone or IP phone) somewhere other than the "subscribed address".

The first conclusion the Commission reached is that "Interconnected VoIP providers must deliver all 911 calls to the customer's local emergency operator."

The second conclusion the Commission reached is that "Interconnected VoIP providers must provide emergency call operators with the ... location information of their customers... Although the customer most provide the location information, the VoIP provider must provide the customer a means of updating this information, whether he or she is at home or away from home." (Emphasis mine.)

For a VoIP provider to deliver 911 calls to a customer's local emergency operator, they have to have E911 trunks to the selective router (tandem switch) serving the PSAP responsible for the local area in which the customer is located. Some carriers (AT&T, SunRocket, AOL) have indicated they may have to limit the availability of their VoIP services to areas in which they are currently able to offer E911 (i.e., areas where they have E911 trunks to the ILEC tandem).

Fine. But what about when someone takes their Vonage WiFi phone to their vacation house in Wisconsin, where Vonage doesn't have E911? Even if Vonage gives them the ability to update their location information - even if Vonage had the ability to figure out their location information autonomously, the holy grail of VoIP E911 - Vonage can't deliver that customer's 911 calls to their local emergency operator, because they don't have the trunks into the local 911 tandem.

Basically, a requirement to deliver all 911 calls to the correct PSAP for nomadic customers is a requirement for every VoIP operator to establish trunking (either directly or through a third party) into the 911 tandem serving every one of the 6200 PSAPs in the country.

Personally, I think it would be amusing to see each of the 400 VoIP providers in North America send a few thousand Access Service Requests to the ILECs, for E911 trunking into every single 911 tandem in the US. We'd see how well the ILECs could service a million ASRs in the next 120 days.

On the other hand, I'd note that Intrado's stock went up 13.44% on Thursday.