FCC Takes Another Look at E911 Rules for VoIP

Regulation Watch

FCC Takes Another Look at E911 Rules for VoIP

By TMCnet Special Guest
, William B. Wilhelm, partner and Jeffrey R. Strenkowski, counsel at the law firm of Bingham McCutchen LLP
  |  October 01, 2011

This article originally appeared in the Oct. 2011 issue of INTERNET TELEPHONY

In July the FCC (News - Alert) released a Notice of Proposed Rulemaking aimed at improving VoIP E911 services. In particular, the NPRM is aimed at revising the scope of services that E911 rules should apply to, and establishing automatic location information requirements for VoIP services.

First, in an effort to broaden its regulatory authority, the NPRM asks if the definition of “interconnected VoIP” (which determines which services are subject to E911 and other FCC rules) should be modified to include outbound-only VoIP services (i.e., services that allow calls to the public switched telephone network, but not from the PSTN), services that can be used with a dial-up Internet connection rather than a broadband connection, and services that connect calls to United States E.164 telephone numbers rather than the PSTN to cover services that provide end-to-end transmission entirely over IP-based networks.

Second, with respect to ALI accuracy, the NPRM does not propose specific requirements but instead seeks comment on whether the commission should adopt general governing principles “for the development of ALI solutions.” It anticipates that some of these solutions will require participation by both over-the-top VoIP providers and broadband providers that provide underlying network connectivity for VoIP calls. It also seeks information on the technologies available for ensuring location accuracy, including in indoor environments for wireless-based services. 

This proceeding is the first significant review of the VoIP E911 rules since the original requirements were established in 2005. Proposed modifications to the definition of interconnected VoIP could significantly expand the commission’s jurisdiction over other types of IP-enabled services that to date have gone largely unregulated by the agency, and the ALI proposals signal a new model for user location accuracy requirements for VoIP and broadband providers.

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Edited by Jennifer Russell