Monday, May 30, 2005

Access to Emergency Services - problem solved? 

If the FCC or other national regulators decide that VOIP providers providing access to or from the (national) PSTN need also to provide access to (national) emergency services and now think the problem is solved, they may make a mistake.

National regulators think by definition only national. They assume national VoIP providers, access to national emergency services, and using national numbering resources - problem solved. Everything else is an Other People Problem (OPP).

  1. This implies that if a VoIP service does not connect to the PSTN, access to emergency services is an OPP.
  2. It is also an OPP, if the VOIP service connects not to my national PSTN but somewhere else.
  3. Only if the VoIP service provider wants to offer the customer a number out of my national number range, the VoIP service provider is providing PATS (national public available telephony service) and has to connect to my national emergency service system, even if the customer wants to have only incalls. Or if the VoIP service provider is only providing outcalls within a gateway connected to my national network.
  4. The VoIP service provider is providing outcalls to the PSTN via another country - this is an OPP.
  5. The VoIP service provider is providing my national customer access to my national emergency services, but may use also the VoIP nomadic anywhere in the world - this is an OPP.
  6. The VoIP service provider providing citizens of other countries (say a Vonage customer based in the US) access to 911 in the US, but now the Vonage customer is nomadic in Austria and dials 911 and this does not (and need not) work - this is an OPP.
  7. A VoIP provider really wants to provide a feasible, consistent and always available access to emergency service to his customers, wherever in the world he currently is? Then the VoIP has to interconnect with +200 different national emergency service systems. Do we think of providing something to ease the VoIP service provider in doing this job.
No, because this is an OPP.

VoIP is a global service (or application) and needs a global solution. So please do not make any final decisions until these global solutions are available (e.g. via IETF ECRIT). But this may take another one or two years.

To draw parallel, we should interpret that emergency service requirement is levied not against voice service, but against access to PSTN. Analogously, in broadband, this requirement should be levied against the access provider and not one particular service provider. Otherwise, the same capability may be replicated ad infinitum.

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