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E911 Ruling: What It All Means

By Yaron Raps, Bruno Codispoti & John Pfaff


The Federal Communications Commission recently took steps to protect consumers by mandating that all providers of Voice over Internet Protocol (VoIP) phone service supply Enhanced 911 (E911) emergency calling capabilities as part of their standard service. The order has the intent of minimizing the likelihood of situations like recent incidents in which users of VoIP dialed 911, but could not connect with 911 operators. The May 19, 2005 order, which requires compliance within 120 days of the published date, marks an important step for maturing VoIP technology as a means of delivering voice calls — but one that is not without its challenges.

Basic 911 Versus E911
In fact there are major differences between basic 911 services and E911. With basic 911, the address information of the calling party is not transferred to the public safety answering point (PSAP) or local emergency centers; the calling party has to inform the operator of his/her location, requiring, therefore, that the customer be conscious and in a condition to speak. Also, basic 911 calls are routed to the PSAP as regular calls via the public switched telephone network (PSTN) without priority status and may not be handled in the same manner as calls made via the E911 network.

By contrast, with E911, a customer’s physical address is stored in a database known as automatic location identification (ALI). During an emergency call, the customer’s service provider routes the call to a dedicated network that has been built to address E911 call needs from a reliability, capacity and technology standpoint. The calling party’s phone line generates an automatic number identification (ANI) signal to the network. The E911 system then reads the ANI and ALI from databases and routes the number to the appropriate PSAP emergency center. Along with that, the caller’s address information is displayed on the dispatch screen, enabling the dispatch of emergency personnel to the site of the emergency. But when companies began offering VoIP, some service providers could not provide E911 services like this because of technical issues and / or business constraints; moreover, some providers would not even attempt to route or complete 911 calls if the customer did not initialize t he 911 service.

However, differences in 911 service and its limitations notwithstanding, most customers choose VoIP because of more attractive pricing. Generally, customers have neither knowledge of nor reason to understand the differences between E911 and basic 911 in terms of operation; customers act on the expectation that the new technology has the same capabilities as the existing technology — and that this voice product works the same as their traditional telephone service.

The FCC order has the effect of imposing E911-like rules on VOIP providers in the near future and outlines the following requirements:

• VoIP providers must deliver all 911 calls to the customer’s local emergency operator. This must be a standard, rather than an optional feature of the service. This means that it will not be up to the customer’s discretion to activate the service; all customers, new and existing, must have this capability.

• VoIP providers must provide emergency operators with the call back number and location information of their customers (e.g., E911) where the emergency operator is capable of receiving it. Although the customer must provide the location information, the VoIP provider must pass to the PSAP the emergency physical address, and also afford the customer a means to update this information, whether he or she is at home/office or away in a different location.

• By the effective date, VoIP providers must inform their customers, both new and existing, of the 911 capabilities and limitations of their service.

• The four major incumbent local exchange carriers, (ILECs) must provide access to the network to any requesting service provider. This includes access for competitive carriers to trunks, selective routers, and E911 databases.

Impact On VoIP Providers
Today VoIP service providers fall into three categories: cable providers such as Cox Communications and Time Warner Cable, wireline such as AT&T and Verizon, and emerging or pure play VoIP providers such as Vonage and Packet8. Some will not need to make modifications to their infrastructures to support the new E911 ruling. Others will face challenges not only related to supporting E911 within the given time, but also to comply with the recent order at the same time that they strive to keep their networks and cost structures intact.

Cable Service Providers: The vast majority of cable providers are already supporting E911. Cable VoIP service is delivered through a customer premise device that is associated with an IP address and a customer’s static physical address, and cable providers use this address as the emergency location. Also, the cable providers are either a licensed competitive local exchange carrier (CLEC) or partner with a CLEC that has direct access to the 911 network. Further, cable companies typically do not offer customers multiple phone numbers with area codes that differ from their physical addresses, or authorize the use of the VoIP service at locations other than the registered service address. As a result, most, if not all, cable companies will require little to no action to comply with the FCC’s ruling.

Wireline Service Providers: Wireline companies have the infrastructure that provides connection and support to the 911 networks. However, in order to stay competitive, most wireline companies are supporting virtual numbers and mobility. For example, customers can choose a New York City number while living in Dallas today and tomorrow they can physically install their VoIP “line” in Chicago. Because the customers are responsible for activating their 911 service, the operator and the authorities would not automatically have knowledge of the customer’s relocation. The wireline companies’ challenge is to enable these new 911 capabilities without being disruptive to customers. Further, to comply with the FCC order, they may also be required to change their sign-up and provision processes if they support multiple virtual numbers.

Emerging/Pure Play Service Providers: The FCC order may have the greatest impact to this segment. The FCC mandate now requires these service providers to connect to 911 networks via their incumbent local exchange carrier (ILEC). Up to this point, the FCC did not mandate the ILEC to accommodate an emerging/pure play’s request to utilize the E911infrastructue. While this requirement will provide these companies with the enabling advantage to afford their customers E911 capability, it comes with the burden of significant additional operational cost. Put simply, some emerging service providers must start from scratch to connect to the network. They must provision and install dedicated 911 circuits. Also, providers will have to wrestle with E911 costs – both operational and 911 surcharges, passing these through to the customer or absorbing the costs depending on their strategy. These additional costs if passed to the customer, potentially make it more difficult to attract and retai n customers and if absorbed, further challenge the provider’s profitability.

A Value Add, But Questions Remain
If VoIP is to reach the mass market, it must perform like plain old telephone service and the FCC ruling goes a long way to accomplishing this and establishing VoIP as a mainstream phone service. This is indeed a plus for the cable and wireline VoIP providers who may begin to see a more level playing field in terms of price competition from the emerging or pure play VoIP providers. Similarly, these service providers will, in turn, realize some beneficial effect in their attempt to gain equal footing with these other multiservice communications companies and in their ability to gain access to not only the E911 network but also to the trunks, selective routers, and E911 databases that are required to provide the enhanced emergency service.

But how will the ruling impact the wireline offering of virtual number, mobility, and the overall industry focus on a person not a place? And, can the pure play VoIP providers add the E911 service and absorb the additional infrastructure cost and still offer new customer’s bundled packages at a lower cost — let alone deal with the price commitments and terms of their existing contracts? Will theses emerging/pure play providers absorb the additional infrastructure and regulatory costs, or will they be forced to pass along the cost to customers in the form of rate increases — a contrast to their initial marketing, which was all about price for features offered?

The FCC’s E911 ruling was not a shot across the bow of VoIP providers. Headlines in the mainstream press took that shot. But one thing is certain: VoIP will not become mainstream until it can solve the E911 issue. In that process, there may be some winners and some losers. Only time will tell. But with the clock ticking, VoIP takes another step towards becoming a mainstream telephone service. IT

Yaron Raps and Bruno Codispoti are solution partners, and John Pfaff, a senior consultant, in the communications practice of BusinessEdge Solutions, Inc., an industry-focused business and technology consulting firm offering operational strategy, business process and systems integration solutions to clients in the communications, life sciences, financial services and insurance industries. For more information, please visit

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