911 in 90 days: How Vonage Is Meeting the Challenge in Canada
At the beginning of April, the Canadian government mandated that all VoIP carriers offering services in Canada must have 911 services within 90 days. Vonage Canada is one of the many VoIP carriers affected by the decision. According to Vonage, there are lessons to be learned from how both Canada and the U.S. have approached the VoIP 911 issue.
The CRTC (Canadian Radio and Telecommunications Commission; the Canadian equivalent of the U.S. Federal Communications Commission), in its April 4th decision requires that "VoIP service providers who provide fixed VoIP service to provide the same level of 9-1-1 emergency service that is provided by the incumbent telephone companies to their existing customers." On May 19th the FCC is widely expected to issue a similar ruling, though it will likely not include the same 90 day timeline that the Canadians have.
The CRTC's directive, though, makes an important distinction between fixed location (non-nomadic) and non-fixed location (nomadic) carriers. Vonage Canada (the Canadian subsidiary of Vonage.com), for example, is considered to be a nomadic carrier. The fixed carriers must provide full E911 services while the non-fixed need only to provide service that is an interim solution that is "comparable to basic 911 service".
The fundamental difference between E911 and basic 911 is that E911 provides the PSAP (Public Safety Answering Point) with the physical location of the call. The physical address location information is transferred to the PSAP via the Automatic Location Information (ALI), which is downloaded from the local exchange carrier database.
Though the CRTC has not mandated E911 for VoIP carriers like Vonage, its definition and requirements for "basic" 911 however still requires a form of address verification. According to Joe Parent, Vice President, Marketing and Business Development at Vonage Canada, 911 calls made over nomadic VoIP carrier networks in Canada must be intercepted and the physical location of the caller must be verified before the call is routed to the appropriate PSAP.
"PSAPs have very specific geographic areas they serve and the Commission is requiring that VoIP providers verify the location of the caller and ensure the call is routed to the PSAP that is equipped to assist the caller," Parent explained. "This is necessary because nomadic services can move by definition. That means that simply using the originating number of the call is insufficient to map the caller to the appropriate PSAP."
Vonage had offered a 911 service in Canada prior to the ruling, but it was optional and did not encompass all users. Beyond making sure that all users will have 911 capabilities, Vonage has also had to implement a call centre organization to intercept all 911 calls in order to ensure that PSAP's receive the physical location of the provider.
"The work to complete these obligations is substantial," Parent noted, "however we are working quite diligently to ensure they are implemented as quickly as possible."
Parent added that Vonage Canada isn't approaching the E911 issue differently due to the 90 day deadline.
"We have to take some interim action in order to comply with the CRTC's interim solution, but that is not inconsistent with our original strategy, nor is it inconsistent with providing a solution that is in the interest of public safety," Parent explained.
The response to the 90 day deadline is not necessarily a long term solution for 911 VoIP services, however. A superior solution (and goal for Vonage Canada) is getting a better level of access to the 911 tandems that deliver the calls to the PSAPs.
"Weand any company offering VoIP services (including Bell and the Cable companies) do not have access to those facilities, so calls are delivered into PSAPs via regular 10 digit administrative telephone numbers within each PSAP," Parent said. "Vonage is participating with other industry players to develop and implement a superior long term solution as quickly as possible."
Vonage has the distinction of being a VoIP carrier both in the US and Canada and has had to deal with the 911 issues in both countries. In Parent's view, there are good lessons to be learned on both sides of the border insofar as each country is dealing with the issue. In particular Parent cited the recent deal that Vonage has struck with Verizon for access to 911 tandems. The agreement, according to Parent, will allow Vonage to deliver a 911 service that is essentially at par with that provided by traditional land line providers in the US.
"I think there is a very good lesson there for all of us on both sides of the border," Parent said. "It is only by taking a proactive and responsible approach to this challenge that superior solutions will be developed and provided to the market."
On the other hand, Parent also noted that in Canada there are lots of examples of cooperation and consultation between a wide range of industry participants to develop solutions to complex issues. In particular Parent cited the CISC (Carrier Interconnect Steering Committee) and the work it is doing to develop standard notification messages that will ensure that the specifics of 911 services via VoIP are effectively and clearly communicated to customers and prospects.
"The CISC proceedings to develop standard notification are an excellent example of how a broad group of industry players (service providers, equipment vendors, regulators, PSAPs, vendors/contractors, etc.) can work together to develop solutions that address the important issues (public safety, consumer education and awareness) without disadvantaging any of the competitors or inhibiting healthy and vibrant competition," Parent said.
"If we as an industry are smart about this, we will take the best of both worlds and the consumer will be the ultimate winner in the end."