All VoIP Calls Should be Subject to Similar 911 Rules, APCO Says

While the FCC previously imposed location-accuracy requirements on VoIP providers that originate and terminate calls on the public switched telephone network, the commission is examining whether similar requirements should apply to increasingly popular VoIP services like SkypeOut that allow outbound only calls. The commission sought comment in an NPRM approved at its July 12 meeting (CD July 13 p7).

"The VoIP industry has gone to great lengths to make their service offerings look, feel, and sound like any other telephone service,” APCO said (http://xrl.us/bmfbo8). “That, in turn, leads the public to believe that any device that can make a telephone is able to reach 911 and provide the same automatic location and call-back information as traditional wireline phone services. ... The Commission’s rules and VoIP service providers must move forward as quickly as possible to make public perception a reality.” APCO said one alternative, “point-of-sale” warnings that 911 service is not available for some VoIP applications, would not be adequate. “A VoIP service purchaser’s need to call 911 may occur long after the sale, when any disclaimers regarding 911 are at best a distant memory,” APCO said.

A mandate imposed on outbound-only services would be “contrary to reasonable user expectations,” the Voice on the Net Coalition said (http://xrl.us/bmfbn7). “The Commission should not depart from the tried and true standard for subjecting a communications service to 911 requirements -- whether that service effectively replaces traditional telephone service -- and impose obligations on one-way VoIP providers that they may not be capable of meeting.” The coalition said the FCC got things right in 2005 when it applied a mandate to VoIP services that largely function like standard phone services, but other VoIP services are viewed differently by the public. “Growing demand for one-way VoIP service is different than changing characteristics or reasonable consumer expectations of those services and does not mean that consumers perceive those services as a replacement for their telephone service,” VON said.

ATIS urged the commission “to allow the industry time to develop a solution or solutions that would be suitable for all types of wireline and wireless broadband access network and over- the-top VoIP providers.” ATIS said it is “committed to working alongside other industry groups, including the Open Mobile Alliance (OMA), the Internet Engineering Task Force (IETF), the Third Generation Partnership Project (3GPP) and the Third Generation Partnership Project 2 (3GPP2), on solution(s) that would serve the interests of the U.S. telecommunications industry and achieve the objectives set forth by the Commission.” ATIS also reminded the commission that “the communications industry considers the provision of location information in emergency situations its highest priority and is actively working on developing solutions for both existing and future technologies” (http://xrl.us/bmfbm8).

AT&T said any requirements should apply to residential but not business services (http://xrl.us/bmfbfw). “Residential customers who use outbound-only VoIP services to reach local numbers ... have a reasonable expectation of being able to use that same service to reach emergency services by dialing 911,” the telco said. It said businesses, such as a computer-controlled dialing system in an outbound call center, “do not have the same expectations regarding the ability to make 911 calls, and they typically have other arrangements in place for access to 911/E911 service.” It would be premature for the FCC to impose automatic location information (ALI) requirements at this time, AT&T said. “Instead, AT&T urges the Commission to submit the ALI-related issues raised in the Notice to the E911 Technical Advisory Group (ETAG) and other industry forums for resolution."

Verizon and Verizon Wireless said any changes approved by the FCC must be in keeping with the New and Emerging Technologies 911 Improvement Act of 2008 and “limited to services that enable calling to substantially all domestic U.S. North American Numbering Plan numbers” (http://xrl.us/bmfbi5). A regulatory mandate “at this time is premature ... given the substantial standards development required for wireline and wireless services alike,” Verizon said: Services that allow callers to make only international calls should not be covered by the requirement.

The Telecommunications Industry Association expressed reservations (http://xrl.us/bmfbgv). The FCC should “recognize that the growth in the VoIP industry has been in significant part due to the current regulatory climate, and that a very strong record first be established that demonstrates technical feasibility and consumer expectations ... before extending VoIP regulations any further,” the group said. “TIA does not believe that this record currently exists, and therefore opposes the proposed general location accuracy governing principles."

CTIA encouraged the FCC to exercise a light regulatory touch as it moves forward on final rules (http://xrl.us/bmfbki). Touching on an issue raised in the NPRM, CTIA said the FCC should rely on the Communications Security, Reliability and Interoperability Council to develop “industry best practices for indoor location accuracy testing and Wi-Fi positioning, as these efforts involve complicated technical issues that are best addressed by a group of interested stakeholders with the necessary technical knowledge.” Indoor testing raises many complex issues, CTIA said, noting work done by the ATIS Emergency Services Interconnection Forum. “ATIS correctly highlighted that it is often difficult to obtain access to certain indoor testing environments, residential buildings in particular,” the association said. “Numerous wireless carriers have affirmed this finding.”