On May 19th the FCC is expected to issue some form of a ruling that will require VoIP carriers to implement E911 services in the immediate near term. Some VoIP carriers claim they're fully ready today, others including giant AT&T believe that there's still work to be done.
According to Time Warner Cable spokesperson Keith Cocozza, Time Warner Cable's Digital Phone VoIP service is already ready for E911. "Time Warner Cable's Digital Phone provides (and has always provided) E911," Cocozza told EnterpriseVoIPplanet.com. "Our customers do not need to do anything special to receive the servicethey are automatically registered when they sign up as a customer."
Covad also claims that it has provided E911 as a fundamental part of its business-class managed VoIP service since it was introduced last year "Enhanced 911 (E911) service has saved countless lives with its ability to instantly pinpoint a distressed callers' location so emergency services can respond immediately," said Jeff Ahlquist, Covad vice president, product management and development. "We recognized this when we launched Covad business-class VoIP service; making E911 a fundamental feature on every single one of our managed VoIP phone lines was crucial."
AT&T has also begun to provision eligible new subscribers with E911 according to AT&T spokesperson Gary Morgenstern. By the end of 2005 AT&T will have implemented a solution for about 75 percent of its' AT&T CallVantage Service base for customers located in AT&T's local footprint.
EnterpriseVoIPplanet.com has learned that AT&T executives met with Michelle Carey, legal advisor to FCC Chairman Kevin Martin, on Friday May 6th, to talk about E911 services. The proceedings of that discussion were detailed in an ex parte letter sent last week by AT&T vice president for federal government affairs Robert W. Quinn, Jr to Marlene H. Dortch, Federal Communications Commission secretary, the text of which has been obtained by EnterpriseVoIPplanet.com.
During the meeting AT&T explained to the FCC the steps it is taking to ensure that an interim E911 solutions is provided for its AT&T CallVantage Service subscribers as quickly as is technically feasible. AT&T also discussed the challenges and complexities it is facing in provisioning E911 services. Thanks to its affiliate AT&T local network services, AT&T's CallVantage VoIP service can utilize local exchange connections in areas where an AT&T local network footprint exists. The sticky problems come in areas where AT&T does not have a local footprint.
"Yet, end users can order and use AT&T CallVantage Service from any location within the U.S. as long as they have a broadband connection," AT&T's ex parte letter states. "AT&T would need to have access to all other selective routers in the country in order to provide nationwide E911 for its VoIP customers."
AT&T suggests that the FCC mandates that all operators of selective routers provide access to other carriers, which would enable nationwide VoIP E911 deployment for IP enabled services.
An estimated one-quarter of AT&T's CallVantage Service customer-base has non-native telephone numbers that do not match the service address's rate center. And an unknown percentage of customers use their service nomadically, according to AT&T, which further limits its ability to provide an E911 solution.
"If the Commission were to order AT&T and other VoIP providers to provide E911 service where selective router access is the only solution and where such access does not exist today, it would be tantamount to ordering the discontinuance of service to existing customers outside of AT&T's CLEC footprint and limiting availability of AT&T CallVantage Service solely to those customers located in AT&T's local footprint," AT&T stated.
Skype, the poster child for nomadic VoIP service has also been in discussion with the FCC about the implications of E911 on its business. EnterpriseVoIPplanet.com has also learned that on May 9, 2005, Skype Communications, S.A. met with FCC Chairman Martin's chief of staff Daniel Gonzalez and Michelle Carey, Martin's legal advisor, and separately with Commissioner Copps and Jessica Rosenworcel, Copps'a legal advisor, on the topic of 911/e911 requirements to IP-enabled services. The details of that discussion are included in an ex parte letter sent by Skype's legal counsel, Henry Goldberg, the text of which was also obtained by EnterpriseVoIPplanet.com
"Skype is concerned that overbroad application of 911/e911 requirements will impede rather than facilitate the provision of emergency services," Skype's letter states. "Skype does not have access to reliable real-time location information for its usersSkype may determine a user's IP address, but IP addresses (in addition to being vulnerable to spoofing) offer only the most general sense of a user's location. "
As such, Skype is currently unable to deliver 911 to call the proper PSAP and according to the letter Skype has warned its users that Skype should not be used for emergency dialing.
In Skype's view the FCC should limit the immediate application of 911 requirements for VoIP to what Skype defines as "fixed-line wireline telephone service".
It's time for the FCC to make a move
Regardless of whether the industry thinks it's too soon or the right time to mandate 911 VoIP services, the FCC probably has to move at this point according to JupiterResearch Analyst Joe Laszlo.
"With more and more media coverage of mishaps resulting from botched VoIP provider handling of 911 calls, it's only a matter of time before the issue creates big problems on both the litigation and legislation fronts, and the FCC should certainly work to forestall that," Laszlo told EnterpriseVoIPplanet.com. "I'm a big believer in a general deregulatory approach to VoIP providers, but keeping consumers confident that their VoIP service isn't going to let them down just when they need it most is also vital for the continued growth of the industry."