IP E911: Better Plan Than FCC’s?

The Federal Communications Commission’s (FCC) mandate to force Voice over IP
companies to provide E911 services to all customers by the end
of the year is a decision wrapped in good intentions but tied to outdated

At least that’s the opinion of several of several major VoIP providers in
the wake of a lawsuit filed
earlier this week to slow or alter the FCC’s order.

“I absolutely share the [FCC’s] concern about E911 services and VoIP,” said Jason
Talley, CEO of VoIP wholesaler Nuvio, which filed the lawsuit. “I think
maybe they were a little exuberant, though. The order was put together
really quick and may not be based on the best technology useable out there.”

Prompted by several well-publicized incidents where VoIP users were unable
to reach 911 in an emergency, the FCC voted in May to impose E911
accessibility on all VoIP providers whose service interconnects with the
public switched telephone network (PSTN).

The mandate requires VoIP providers to not only make E911 services available
to customers, but also dictates that all providers inform their subscribers
of the possible limitations of the E911 service, particularly in regards to
the specific location of the caller.

VoIP subscribers have the ability to use the service wherever a broadband
connection is available, creating enormous location problems for first
responders. The FCC is not requiring Internet telephone services to provide
nomadic 911 but only that all VoIP subscribers have access to emergency
services for their static addresses.

“Connecting to the current E911 system is difficult, expensive and time
consuming,” Vonage, the naiton’s largest independent VoIP provider, wrote in
a filing to the FCC last week. “To enable E911 service, VoIP providers must
obtain access to ILEC (incumbent local exchange carriers) systems,
interconnection facilities, numbering resources, PSAPs (public service
answering points) and other critical elements that traditional telephone
companies employ to provide E911 service.”

That’s the point, said Talley.

Connecting packet-based VoIP services through the switch-based copper lines
of the PSTN, he claims, is a plan going in the wrong direction.

“IP through routers, now that’s neat stuff,” he said. “As it is now, we
can’t go to the next generation of E911 services.”

Those services could include maps, photos and other supporting data for
first responders.

Vonage believes the key to the next generation should be the creation of a
new, open platform, IP-based architecture.

In its FCC comments, Vonage
encourages the FCC to develop a limited number of network access points
(NAPs), points of interconnection at discrete locations which are similar to
the metropolitan-area exchanges used for the handling of Internet traffic.

“Such E911 NAPs would provide for the centralized collection of E911 calls
at a limited number of access points in a manner that is consistent with and
analogous to the network architecture currently in place for Internet
service providers for the exchange of IP traffic,” Vonage told the FCC.

Under that scenario, Vonage says, VoIP providers would deliver calls in IP
format directly to the NAPs without conversion to to PSTN transmission

“Instead of requiring dedicated trunk groups to an enormous number of
selective routers, service providers could use secure, dedicated connections
to those NAPs,” Vonage wrote.

Unfortunately for the VoIP providers, that’s not the FCC’s current plan.

“[The FCC mandate] affects all of us,” Talley said. “Others weren’t doing
anything about it, and we felt [the lawsuit] had to be done.”

The goal of the litigation is to delay the imposition of the FCC’s E911 mandate
for VoIP providers. With a delay, Talley said, perhaps a 21st-century E911
plan could be put in place.

Without a delay, 21st-century technology will be crammed into a 20th-century

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