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The FCC VoIP E9-1-1 Mandate: Doom Or Zoom?

By Tim Lorello


Over the last few months, we have been discussing the potential impact of E9-1-1 on the deployment of VoIP adoption. VoIP has the potential of revolutionizing the telecommunications industry, by providing a cost-effective method, using data communications, to replace various wireline and wireless communication methods in use today.

However, it is important to know that today, wireline and wireless both provide the ability to automatically deliver a callers location to an Emergency Services Responder when the user places a call to 9-1-1. This automatic location delivery bridges all languages, passes information even when the caller cannot speak, and enables the Emergency Telecommunicator (the person taking the call on behalf of Public Safety,) to focus on the nature of the emergency, rather than your current location, thereby saving many minutes in sending help and, ultimately, saving lives in the process. In many cases, VoIP does not provide location information automatically to Public Safety. So we have posed the question: will this Enhanced 9-1-1 (E9-1-1) capability prove to be the stumbling stone to VoIP? Lurking in the background of our discussion was the very real possibility of the FCC mandating some form of E9-1-1 service, as it did for wireless. On June 29th and becoming effective on July 29th, that possibility became a reality the FCC, under the leadership of its new Chairman Kevin Martin, has required all VoIP Service Providers (VSPs) to provide E9-1-1 service to their customers regardless of how or where they are using the service. Our next step is to analyze this FCC Order and determine whether this bodes well or ill for the VoIP industry.

Whats In A Name?
The first part of this analysis must be to clearly determine to whom this Order applies. As one might expect when lawyers are involved, this particular point is under heated debate. According to the FCC Order, the mandate applies only to providers of interconnected VoIP service. The FCC defined this to mean that the service must be connected to the Public Switched Telephone Network (PSTN) for the purposes of receiving calls from and placing calls to the PSTN. This is a very common sense approach to the problem and establishes the basic underlying principle of the Order: if the VoIP user can expect the service to work like a typical wireline or wireless service, then it must also provide E9-1-1. As a result, those services which only exchange data, such as instant messaging, or those voice services which only allow interconnection to other users of the same service, such as certain versions of Skype, would not be treated as interconnected VoIP service. This is the classic if it walks like a duck and quacks like a duck, its a duck definition. The debate now rages around whether certain services that allow PSTN interconnection from a soft phone environment (e.g., making calls from your laptop or desktop computer utilizing a headset) are actually interconnected and affected by the Order. If I were to place bets, I would place them on the side of the safety of the consumer. If the soft phone directly or indirectly encourages the consumer to use it as a primary communication device, I believe that VSP will be impacted by the Order.

What And When?
The VSP has a number of very specific tasks to perform over the next few months.

First, by end of November, all customers of a VSP must provide Enhanced 9-1-1 as part of their service offering. The subscriber cannot opt-out of the service.

Second, by end of November, the VSP must transmit all 9-1-1 calls to the appropriate Public Safety Answering Point (PSAP) that services the callers registered location. With the call, the VSP must automatically transmit the callers registered location and a call back number (in cases where the call is disconnected, the PSAP can take action to reestablish communication). This is a change from the approach many VSPs use today which routes the 9-1-1 call to an administrative line at the PSAP a 10-digit phone number that pretty much anyone may call. I like to call this the side door to the PSAP since it is not always staffed 24 hours a day and sometimes does not have the same capabilities that the front door to the Telecommunicator possesses, such as call transfer or dispatch access.

Third, by end of November, VSPs must obtain location information from their customers, and this must be done prior to initiation of service. For those VSPs that allow their users to access their VoIP service from multiple locations, the VSP must further provide a method by which the user may update their registered location at will and in a timely manner, including one method that requires use only of the Customer Premise Equipment necessary to access the VoIP service. In short, you must get the callers location; the caller must be able to update it at will, and he/she must be able to use the phone to do it!

Fourth, by end of November, the VSP must file a letter of compliance with the FCC.

Fifth, by end of July, the VSP must notify the customer of their compliance with the FCC order and how the VSPs E911 offering differs from traditional E911 offers. In particular, the VSP must get from the end user a positive acknowledgement of reception of this information.

Doom Or Zoom?
What does all of this mean for the VSP? Is this the death knell for VoIP or will this propel it even faster into becoming a mainstream communication medium? The jury is still out on this verdict, but all indications are that this FCC Order has galvanized the industry into action. Though the terms of the Order are likely to be debated with the FCC, and though there continue to be technical, business, and regulatory impediments to providing E911 to VoIP users, this Order has forced all participants to determine how they should and will provide this life-saving service. Competitors have become collaborators. And, in the end, the VoIP consumers will benefit. It is likely that some VSPs will change the way in which they offer their VoIP services. Others may decide it is no longer feasible for them to offer service, and they will disappear from the VoIP landscape. But it has always been my contention that E911 is a required feature for any serious communications service. The average consumer, who does not anti cipate the emergency, expects the service to work automatically when tragedy strikes. Thus, I believe that this Order will accelerate the process by which VoIP will take a rightful place as a mainstream communications medium. IT

Tim Lorello is senior vice president and chief marketing officer for TeleCommunication Systems (TCS). For more information, please visit the company online at

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