Monday, June 06, 2005

My first 2c worth on the FCC 911 proposed rulemaking 

Now having read the whole document (puh), my first take is the following:

This is a ruling with a very light touch. It basically requires:
  1. access to the selective router
  2. as a minum access to the default PSAP of the state.
  3. subscriber selfprovisioning of location
  4. training of subscribers (E911 for Dummies)
Access to the selective router seems the most controversial issue, but the FCC states all over the place that they will monitor this closely.

Since I have the opinion that any VoIP provider and finally any device attached to the Internet (ECRIT) should provide the capability to access emergency services, I was at first sight disappointed that the ruling was only for "interconnected" VoIP providers, but the further reading showed that this is considered only as first step, and the document clearly proposed this as future aim.

Really disappointing from an European view is the somewhat autistic approach: abroad means in the US basically still in the US. But this autistic view is in this case not typical US, as one may assume, it is more typical for national regulators.

Nowhere is mentioned (also not in future approaches) what happens if an US citizen (away from home) is leaving the country or an alien is using his VoIP service in the US and which rules should apply in this case (ok, maybe I missed it).

Does a VoIP provider needs to provide 911 access:
  • for US citizens only?
  • for US residents (US home address)?
  • for anybody having a US IN-number?
  • for anybody beeing temporarily in the US?
Questions over questions.

The most informative part of the document is the section IV Notice on Proposed Rulemaking (NPRM), because the tons of questions raised here show the issues still open and also answer some questions I had reading "Annex B - Final Rules" first.

I and obviously others too had a problem with the following definition: An interconnected Voice over Internet protocol (VoIP) service is a service that: (1) enables real-time, two-way voice communications; ...

Is two-way meant in the sense of a "full-duplex" conversation (in contrast to push-to-talk) or is it the possibility of having both originating and terminating calls?

The NPRM section 58 makes it clear: it is the latter, because the following questions are raised:
58. We also seek comment on issues raised by our decision today to impose E911 service obligations on providers of interconnected VoIP services. The scope of today’s Order is limited to providers of interconnected VoIP services. We seek comment on whether the Commission should extend these obligations, or similar obligations, to providers of other VoIP services that are not covered by the rules adopted today. For instance, 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?
Good questions, but:
We tentatively conclude 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 rules we adopt in today’s Order if a user can combine those separate offerings or can use them simultaneously or in immediate succession.
Immediate succession? 5 seconds? 5 minutes?

So what if I use the Pulver communicator to receive calls from and immediately (whatever that means) use Skypeout afterwards. Does Skype now need to provide me a 911 access? Skype has no idea that I use the Pulver Communicator with (BTW, this is possible now, get the key from here),
Are there any other services upon which the Commission should impose E911 obligations, including any IP-based voice services that do not require a broadband connection?
Now this is a cute one. What is a non-broadband connection? Bsically a dial-up via POTS or ISDN. So you have 911 built in. But how does Skype know you are connected via dialup only.

I fear these discussions will go on until finally all VoIP services and each IP connection has to provide access to emergency services.

Just a last point: why not demanding that in each state there has to be a default emergency service routing proxy providing p-ANIs, and with access to the selective router and at least to the state default PSAP. In this case any VoIP provider (and not only "interconnected" could immediately provide access to 911 easily.


Considering that Access to Emergency Services is important, this ruling is not so bad as a first tentative take, it set the lines other regulators will follow. This is important, because it may help VoIP providers in other countries if their regulators want to overdo it.

But is also shows clearly that there are still many open issues and that there is still a lot of work required to be done. I also appreciate the work NENA is doing both in direction I2 and I3.

Light touch? Have you read how soon after the ruling this must be implemented? How soon must all customers be notified and sent warning labels? And how all customers must actively ack receipt & understanding? And that a non-computer interface (TUI/IVR) must be setup to enable a customer to update their address in real time? Maybe that is just my reading or misunderstanding but it seems a heavy touch.
My reading: It doesn't matter what you as a user do; it matters what the VoIP service provider offers. Skype offers In and Out, so the FCC tentatively concludes Skype meets the fourth condition. If a provider offers only a dialout to PSTN service with no dialin from PSTN capability, they are not bound by the E911 requirements (though they might be later).
What if I use (as US citizen) an UK SkypeIn number and SkypeOut?
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