VoIP E911—What a mess!

Sat, 12/31/2005 - 7:00pm
Jeffrey Krauss, President of Telecommunications and Technology Policy

Two years ago, in my December 2003 CED column (, I wrote about the problems of integrating voice-over-IP (VoIP) services into the country's E911 network. It was not until early 2005 that it exploded onto the front page, when the FCC first became aware of an incident in which a VoIP user dialed 911 during a home invasion burglary, but the call was blocked. But in trying to deal with the problem, the FCC has adopted rules that imposed enormous burdens on VoIP vendors, caused some major telcos to do some stupid things in order to comply, and created a huge mess. And Congress has stepped in to try to clean it up.

Jeffrey Krauss
I wrote about the problem of trying to supply the location of a nomadic VoIP user. It never occurred to me that many 911 calls from VoIP subscribers would not go through at all. But I had forgotten about the anti-competitive histories of incumbent local telephone companies (ILECs). They control the trunks and switches that provide the E911 service and that route 911 calls to Public Safety Answering Points (PSAP). For many years, their policy was to refuse to interconnect with competitors. It always took either FCC orders or legislation to force them to interconnect. And E911 was no different—they refused to interconnect with VoIP services to allow 911 calls to go through to a PSAP.

So with lightning speed, the FCC stepped in with an Order released in June 2005 that forced VoIP vendors to "obtain affirmative acknowledgements, by July 29, 2005, from 100 percent of their subscribers that they have read and understood an advisory concerning the limitations of their E911 service," and to disconnect customers who didn't reply. It further required that they provide E911 capabilities to all remaining customers by the end of November 2005.

It soon became clear that the July 29 date was wildly impractical, and that began a series of postponements by the FCC's Enforcement Bureau. Just before July 29, the date was extended to August 29. In late August it was extended to September 28, then to October 31, and then to November 28. Any company unable to reach 100 percent acknowledgement by those dates had to submit reports and explanations, and by now the FCC docket file (WC Docket No. 05-196) is overflowing. I was amused by one of the justifications I read—evidently many VoIP services are used as fax lines. It's hard to get an affirmative acknowledgement when the VoIP vendor uses a live operator to call customers, and a fax machine answers. I wonder how many 911 emergency calls come from fax machines.

The FCC soon recognized that many VoIP customers, particularly in rural areas, are still unable to make 911 calls. The FCC guidance for the November compliance date required the following:

To the extent a provider has not achieved full 911 compliance with the requirements of the VoIP 911 Order in all areas of the country by November 28, 2005, the provider should: 1) describe in detail, either in narrative form or by map, the areas of the country, on a MSA basis, where it is in full compliance and those in which it is not; and 2) describe in detail its plans for coming into full compliance with the requirements of the order, including its anticipated timeframe for such compliance.

That leaves the question of determining the location of the caller. Remember that the FCC first began looking at this issue for cellular phone services in 1994, and adopted numerous compliance dates but kept postponing them and granting waivers to individual cellular operators. It was not until 2004, 10 years after the proceeding began, that a significant number of cellular networks and cellular phones are E911 compliant and can provide a cellular caller's location to a PSAP.

So far as I know, nobody has come up with a technical solution for locating a nomadic VoIP subscriber. But AT&T, MCI and Verizon have come up with stupid administrative solutions. If you move around, they disable your service! When you sign up for these services, you must register your location. All three of them use proprietary VoIP terminal adapters, and they can detect when the terminal adapter is disconnected or turned off. So anytime this is detected, they suspend your service until you call customer service and report your new location. And then it can take several days to update the E911 databases with your new location.

And the FCC has now prohibited VoIP companies from accepting new customers unless the customers have full 911 access. But because some VoIP companies don't know their customers' locations, they can't tell whether the customers have 911 access or not. Catch 22!

In addition, Congress is involved. In early November, the Senate Commerce Committee passed S.1063, which would force ILECs to interconnect with VoIP vendors, and require the FCC to waive its VoIP E911 location requirements for portable or nomadic service if they are technically or operationally infeasible.

If eventually enacted into law, this will be one time that the Congress cleans up the FCC's mess, rather than vice versa.

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