Sunday, September 04, 2005

Jeff Pulver, Emergency Services and VoIP in Germany 

It is really interesting to watch how things go round globally via blogs. Jeff is pointing on his blog today under the heading Traditional Carriers in Germany Fight to Impose Emergency Response Obligations on VoIP Providers to an article on Heise online: Breko Association critical of emergency call special clause for VoIP providers.

The German Association of Regional and Local Telecommunications Companies (BREKO) is objecting to the possibility that the obligation of providers of Voice-over-IP (VoIP) services to ensure emergency call functions in the case of VoIP phone calls might be waived for a period of three years. According to BREKO, which represents the interests of telecommunications companies that offer fixed-line telephony on a regional level, an exemption clause to this effect is to be found in an Amendment to the German Telecommunications Act (TKG). This amendment the mediation committee that mediates between the Bundesrat, the upper chamber of Germany's federal parliament, and the Bundestag, the lower chamber, is to consider on Monday.

Jeff is of course exactly at the point when he says:

If my reading of the press account is accurate, BREKO, which represents the interests of telecommunications companies that offer fixed-line telephony, and view VoIP providers as a direct threat to their existing revenue streams, expressed concern that VoIP-based emergency calls are not relayed to the nearest emergency coordination center and that the location of the person in need cannot be determined automatically.

Frankly, I have been somewhat surprised that the traditional providers in America have not been quite so vocal about requiring VoIP to provide equivalent E-911 capabilities in the US ...

to comes finally to the correct conclusion:

Motivated by a desire for a competitive edge over new entrants, the traditional phone companies in Germany seem to make clear that VoIP providers should be subject to identical emergency response obligations, wearing their true motivation on their sleeve -- keeping would be competitors out of the market, rather than ensuring the best possible advanced emergency response capability that IP technology would afford.

This aligns completely with my own observations during the discussions in Europe and Austria. And this behaviour is not restricted to fixed-line operators, also the mobile (wireless) operators use the same line of argumentation, even if they sometimes walk on very thin ice. Sometimes representatives of mobile operators get carried away in the heated discussions and argue also with the problem of VoIP in case of a power outage at the CPE, seconds before their left half of the brain intervenes and stop them talking. (How could I know what I think before I hear what I say).

What I consider very amusing related to this discussion is that everybody is of course citing the FCC order, e.g. BREKO in the related press relase (September 2nd):

Derzeit kann bei der IP-basierten Telefonie im mobilen Einsatz ein Notruf nicht zur nächstgelegenen Rettungsleitstelle übermittelt und der Standort des Hilfsbedürftigen nicht automatisch ermittelt werden. In den USA wurden VoIP-Anbieter nach Fällen von missglückten Notrufen von der dortigen Regulierungsbehörde FCC (Federal Communications Commission) ultimativ aufgefordert, den erweiterten Zugang zur Notrufnummer 911 bis Ende November 2005 sicherzustellen oder die Dienste zu sperren.

Heise online is translating this and also giving the proper links:

After a string of unsuccessful emergency calls the Federal Communications Commission (FCC) of the United States has given VoIP providers an ultimatum until the end of November 2005 to provide enhanced access to the emergency number 911, valid throughout the United States. VoIP providers are putting up resistance to this demand. Among other things the FCC has published a Consumer Advisory on VoIP and 9-1-1 Service and a decision ordering VoIP providers to ensure enhanced access to 911 emergency services by the end of November 2005 or face the blocking of their services (PDF file, 436 kilobyte, approximately 980 pages).

It is obvious that most citing the FCC document has read it (maybe scared off by the approximately 980 pages - luckily it is only 90 pages ;-), demonstrated by the following paragraph:

The association whose members compete with VoIP providers points out that VoIP-based emergency calls are not relayed to the nearest emergency coordination center and that the location of the person in need cannot be determined automatically. On the other hand for its customers the VoIP provider Sipgate has since July of this year made a VoIP emergency call function available throughout the whole of Germany. However, the VoIP provider concedes that this solution does not solve the problem of how to locate a calling party with a nomadic VoIP call number in the event of a so-called "groan call." The latter denotes calls made to the emergency numbers 110 or 112 in which the calling party is no longer able to provide information about his or her whereabouts.

Nobody mentions or gets the idea that the Sipgate proposal nearly exactly matches the FCC requirements: routing the call by user-self provided addresses and is not requesting that the location is determined automatically.

Which again shows the true motivations and also aligns with my private observations: Nobody citing the FCC document in Europe as a counter example against VoIP has read it.

It should also be mentioned that the regulators involved have a much better understanding of the problem then the operators. Their motivation to waive some requirements to allow emergency calls, even if not perfect, for some limited period of time is the simple insight that a imperfect emergency call is always better then none. Talking about imperfect solutions: fixed-line and mobile operators should be a bit carefull in promoting some issues - not to shoot themselves finally into the foot.

Since nobody reads the FCC document in Europe, there is also no idea that the whole issue is only considered as temporarily solution until a better solution on IP is in place.

If you mention e.g. IETF ECRIT here, you basically earn a blank stare.

I think some of these issues will be discussed in two weeks at the Fall VON 2005 in Boston at the panel discussion on

Emergency Services for Internet Communications
Wednesday, September 21, 2005, 10:30am - 11:45am

The Internet standards community has focused on making Emergency Services that work for nomadic communications. This panel is an update of what’s going on at the IETF and what’s needed to complete the standards work and get it implemented in today’s marketplace.

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