Ever since the Federal Communications Commission (FCC) issued its now-famous ruling in May 2005, the topic of Emergency 911 (E911) for Voice-over-IP (VoIP) has been a hot one in the internet telephony industry.

 

Bryan Martin, CEO of 8x8, Inc. recently chatted with TMCnet.com to explain how his company dealt with--and continues to deal with--the E911 issue. His insights offer a service-provider perspective on the topic.

 

It all started in November, 2002, when 8x8 launched it VoIP service, Packet8. At that time, Martin told TMCnet.com, “there wasn’t a good solution for E911 out there.” 8x8 partnered with Level 3 Communications to provide termination of Public Switched Telephone Network (PSTN) traffic, much as Vonage and AT&T used Intrado’s blind-call forward service.

 

Here’s how that worked, Martin says: 911 calls from VoIP lines were forwarded to fixed-line numbers belonging to Public Safety Answering Points (PSAPs). But, because of the databases being used, calls sometimes got forwarded to operators who weren’t trained to handle requests for emergency service. 

 

Martin stresses that, because of this problem, 8x8 marketed Packet8 as a secondary voice service only, not a replacement for the customer’s regular phone line.

 

Then, in late 2003, Level 3 approached 8x8 about forming a partnership to connect Packet8 with the real E911 network. It took about six months to develop the front-end provisioning necessary to implement the change, Martin said. Packet8’s full-service, optional E911 functionality was launched in June 2004.

 

E911 for Packet8 was optional at the time because it was not available all areas. Initially, it cost subscribers an additional $3 a month; that was later lowered to $1.50. Martin said 8x8’s goal was merely to recoup the costs associated with providing the service.

 

By May 2005, Martin recalls, Vonage, AT&T and a few other small VoIP players were still using Intrado’s forwarding service for E911—and were getting into some trouble because of it. In response, the FCC issued its ruling, which wasn’t that big a surprise to Martin. “Everyone predicted that it would happen,” he remembers.

 

The FCC’s ruling, according to Martin, was mostly aimed at Vonage and AT&T. But it did point a finger at 8x8 with regard to E911 being an optional feature of VoIP service.

 

Martin’s argument for making the service optional was that, at the time, only about six percent of 8x8 subscribers were signing up for Packet8 E911. “That meant people didn’t want to pay for it,” he said.

 

The FCC disagreed with Martin’s logic, and required that VoIP providers make E911 available as a non-optional feature to all subscribers.

 

To drive home how seriously it was taking the existing problems with VoIP E911, the FCC gave all VoIP providers a mere 30 days to proactively notify customers of the limitations of VoIP E911 service, and to file a report at the end of that period stating how many customers had responded to the notification, Martin said.

 

Everyone knew that getting a 100 percent response in 30 days wasn’t possible, and unsurprisingly the FCC ended up granting several extensions.

 

8x8 initially, and very quickly, reached and got responses from 80 percent of its customers, Martin said. Those who did not respond were treated to a reminder recording before every VoIP called they made.

 

By summer’s end, 8x8 had reached more than 95 percent of its customers. “We got down to such a small number that we suspended the service of those who hadn't responded by August 30,” Martin said. “We were very proactive.”

 

Although 8x8 managed to comply fairly quickly with the notification part of the FCC ruling, the company still had to address another section: the issue of phone number addressing and VoIP mobility.

 

Unlike traditional phone lines, which are registered to a specific address and can’t be moved without notifying the phone company, VoIP lines are mobile. The customer can register a VoIP number in New York City and place calls using that number from any location.

 

The problem was how to keep track of where VoIP lines were located so that 911 calls would get routed to the correct local PSAPs.

 

The FCC addressed this problem, Martin said, by requiring VoIP providers to make their phone number addressing databases accessible to customers, so that they could update their own locations.

 

In order to comply with this part of the order, 8x8 decided to partner with a company called TCS, which maintains its own address database outside the regular phone network. That database is used to classify VoIP numbers as mobile, and maintain a record of where each line is located.

 

“When you call 911, we do a dip out of that database to get your latest address,” Martin explains.

 

8x8’s mobile-compliant E911 service was operational Nov. 28, 2005, Martin says. Today, the company continues to partner with TCS in providing E911 service to Packet8 customers.

 

When TMCnet.com asked Martin how the customer-updated phone address system has worked out, he gave us an earful. Clearly, the topic is a point of contention between 8x8’s CEO and the FCC.

 

The problem, Martin says, is that allowing customers to update their own address records removes an important layer of validation. Although software can be used to verify some aspects of an address entry, information is still sometimes typed incorrectly, or falsified, and as a result PSAPs may be unable to determine where a caller is located.

 

“We will always have issues if customer can update their own address record,” Martin emphasizes.

 

Adding complexity to the problem, Martin adds, is the fact that—unlike incumbent carriers—VoIP providers aren’t protected by the FCC from lawsuits that may result from incorrectly routed 911 calls.

 

Since VoIP providers like 8x8 can’t afford to take the risk of being sued when a 911 call doesn’t reach the correct PSAP, most of them use national call centers set up to ensure that callers get the help they need.

 

8x8 uses a national call center set up and maintained by TCS. Martin explains that if a Packet8 subscriber places a call from a VoIP number that doesn’t have an identifiable address, the call is routed to the TCS center where an operator helps connect the person in trouble with appropriate, local help.

 

When a call comes in to the center, the first thing the operator asks is whether the caller needs fire, police, or medical help. Then, they ask the caller to verify their address. Once this information is established, the operator stays on the line until the caller is connected with either a local PSAP or a local first responder.

 

In cases where the caller can’t talk, or the address can’t be determined, the operator can route the call to 8x8 directly for address verification. “We can go into the user account, and provide all addresses available,” Martin notes.

 

“I've explained to the FCC many times, I believe this is a temporary thing,” Martin says about the national call center. But, he adds, in the world of telephony “temporary” can be a long time.

 

So what would be a long-term solution?

 

“I would love the FCC to federalize a system that all these services can use,” Martin says.  He acknowledges that emergency services needs to be run at the local level, but says that a network to connect callers with those services should be national in scope.

 

So far, according to Martin, the FCC has not responded adequately to VoIP providers’ concerns about how the current E911 system is run. Also, Martin says, the FCC needs to address the issue of how PSAPs get compensated for their services.

 

In the old world of telephony, fixed phone lines were taxed, and those taxes went to the PSAP. But VoIP lines can roam anywhere; someone with a Manhattan number could take their phone to Las Angeles and call 911 from there.

 

The fair thing would be to compensate the local responders where the emergency service is provided. But as it stands, Martin says, “funding is based on phone number.” As a result, “No-one knows how to pay anyone.” He adds that, “The PSAPs need to be paid. We just need an FCC policy on how they should be paid.”

 

Last fall, Martin says, the FCC set up a task force charged with enforcing the E911 order, and offering guidance to VoIP carriers in terms of how to proceed.

 

But so far, according to Martin, the task force hasn’t been much help. “They really haven't done anything that I've seen, other than set up a website,” he says.

 

Until more guidance is provided, 8x8 is doing its best to comply with FCC orders and expand its customer base at the same time. Since Packet8 service can’t be sold in any area where E911 service isn’t established, 8x8 is gradually becoming certified, one at a time, with all PSAPs in the U.S.

 

There are more than 6,000 PSAPs in the country, Martin says, and they are all independent of each other, so getting certified is a time-consuming process. “Some of them we've had no issues with,” he said. “Some will refuse to accept calls unless you go through their testing.”

 

In some cases, that’s a simple matter. In others, it’s more complicated. Martin recalls one PSAP, for example, that wouldn’t certify 8x8 because they wanted the company to provide TTY support. Problem is, TTY and Packet8 VoIP are incompatible. “None of my customers are using TTYs,” Martin says.

 

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