VoIP and ENUM

Jeff reports that the FCC's "E911 Requirements for IP-Enabled Service Providers" Order was published in the Federal Register today. He also gives the timeline, ending on:

28.11.2005 -- 120 day deadline for compliance

Jeff is also making those not offering what would currently satisfy the definition of an "Interconnected VoIP Service," to be aware that the Notice attached to the Order asking whether the FCC should extend E911 obligations to providers of other VoIP services that are not covered by the rules adopted in the current Order:

For instance, the FCC asks what E911 obligations, if any, should apply to VoIP services that are not fully interconnected to the PSTN? Specifically, should E911 obligations apply to VoIP services that enable users to terminate calls to the PSTN but do not permit users to receive calls that originate on the PSTN? Should E911 obligations apply to the converse situation in which a VoIP service enables users to receive calls from the PSTN but does not permit the user to make calls terminating to the PSTN? The FCC tentatively concluded that "a provider of a VoIP service offering that permits users generally to receive calls that originate on the PSTN and separately makes available a different offering that permits users generally to terminate calls to the PSTN should be subject to the E911 obligations if a user can combine those separate offerings or can use them simultaneously or in immediate succession." Comments are due August 15 and Reply Comments are due September 12.

As I already stated is the final goal to make emergency services finally available from any device connected to the Internet. So the discussion if the availability of a connection to the PSTN is provided (in or out or up and down, by whom and if you have a phone number) is useless, because it distracts only from the basic issue.

Regulators tend also to think nationally and do not care about foreigners visiting a country or own citizens visiting other countries, but here a global solution is necessary.

There are three high priority issues:

1. IETF WG ECRIT should be supported by any means to provide a global solution as soon as possible.

2. PSAPs should start now to provide access from the Internet.

3. In the meantime every country should start immediately to think about providing Emergency Service Routing Proxies (ESRP) accessible by any VoIP provider to accept emergency calls and feed them via gateways into the national PSTN network and route these calls either to default PSAPs or do the proper mapping if a location is provided. The ESRP should also provide pseudo-CLI to give the PSAPs access to the location data and also enable callback to VoIP providers not using E.164 numbers. PSAPs offering access from the Internet will already be accessed directly, either via the ESRP or via a global mapping database (e.g. LUMP).

VoIP providers would have in such a way easy access to emergency services globally and would have no excuse not to provide such an access. Within one year at least access to a national or state default PSAP could be provided in any country from any VoIP enabled device, except from VPN-users and they could be made aware of the problem and would be required to enter their location manually as now required.

Putting the efforts in these activities would be much more productive then discussing what an "interconnected" VoIP provider is.