December 2008 | Volume 11/ Number 12
Regulation Watch
VoIP E-911 Interconnection — New Rights Granted Under the NET 911 ActThe FCC (News - Alert) recently released an Order adopting regulations under the NET 911 Improvement Act (NET 911 Act) governing access to 911 and E911 capabilities by interconnected VoIP providers (IVPs). The rules provide IVPs with significant new rights to interconnection. Under the rules IVPs now have a right of access to the E911 infrastructure equal to the access rights made available to mobile providers. The FCC noted that, “in a typical local architecture, ‘capabilities’ will include: the Selective Router; the trunk line(s) between the Selective Router and the PSAP(s); the ALI Database; the SR Database; the DBMS, the MSAG; p-ANIs; ESNs; mobile switching center capabilities; mobile positioning center capabilities; shell records; the data circuits connecting these elements; and the network elements, features, processes, and agreements necessary to enable the use of these elements.” Furthermore the Order specifies that that the rates, terms, and conditions of IVP access to E911 capabilities must in all instances be reasonable. The FCC determined that one indicia of reasonableness will be whether the rates, terms, and conditions under which E911 capabilities are made available to IVPs are the same as the rates, terms, and conditions made available to mobile providers. The order did not include any conclusions, even tentative, on the issue of VoIP service provided via a dual-mode headset on a WiFi (News - Alert) connection and the use of “last known cell” location technology. The Order similarly omits any discussion of creating a PSAP and/or Selective Router registry, dispute resolution between IVPs and capability owners, delegation to state or local authorities to regulate any portion of the FCC’s new rules, enforcement of the new rules, specific pricing standards, demarcation points between capability owners and IVPs, and other items. In sum, we view the Order as a significant win for IVPs IT William B. Wilhelm (News - Alert) is a partner in the law firm of Bingham McCutchen LLP. For more information please visit them online at www.bingham.com. The preceding represents the views of the author and does not necessarily represent the views of Bingham McCutchen LLP or its clients. Today @ TMC
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