FCC rules should be based on the assumption that the...

to a July 13 FCC notice of proposed rulemaking. “Even if a VoIP service subscriber uses a particular service without an expectation of making domestic outbound calls (let alone calling 911), to the extent a phone-like device is capable of doing so, others (such as a family member, friend, visitor, customer, or employee of a subscriber) may use that device in an emergency situation with a clear expectation that they will be able reach 911,” APCO said (http://xrl.us/bmho3t). “A subscriber might also obtain a VoIP service with the intention of using it in narrow circumstances (e.g., international calls), and then begin to use it more broadly over time, creating new expectations of its capabilities by the time an emergency occurs.” APCO conceded “there may be some basis for creating FCC-recognized consensus guidelines and standard of care best practices for situations that clearly do (or do not) create reasonable expectations of 911 capability” but those cases should be seen as an exception, APCO said. The National Emergency Number Association largely agreed with APCO in its reply comments. “Since the Commission adopted its existing definition of interconnected VoIP service in 2005, the consumer market for such service has changed dramatically,” NENA said (http://xrl.us/bmho4b). “While it was initially only facilities-based VoIP providers who marketed their services as true replacements for home telephone service, non-facilities-based providers now aggressively market their services to residential subscribers, emphasizing low cost and ease of use as key selling points. Indeed, even services that have not marketed themselves as replacements for POTS [plain old telephone service] are increasingly offering products that emulate the residential POTS experience.” The FCC previously imposed location-accuracy requirements on VoIP providers that originate and terminate calls on the public switched telephone network and is now 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).