VoIP Providers Say E-911 Location Mandate Won’t Work
VoIP providers urged the FCC not to apply wireless- style E-911 location standards to their services, saying they can’t offer automatic location yet but are working on it. “There is no technically feasible method for VoIP providers to provide a customer’s location automatically when the customer calls 911,” Verizon said in a reply filed in a broader proceeding on improving wireless E-911 location standards (CD Aug 22 p3). Wireless accuracy requirements for VoIP services could “slow implementation of innovative VoIP solutions,” warned the VON Coalition. Without a “technically feasible approach to autolocation,” imposing a mandate on VoIP providers “would do more harm than good at this point,” the NCTA said.
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The commission should “allow more time for the industry to address these issues and defer any further consideration of adopting automatic location requirements or location accuracy standards until it knows what capabilities are technically and commercially feasible,” Verizon said. Interconnected VoIP services “present unique challenges for providing automatic location information,” the Bell said. GPS hasn’t worked for many users; other automatic location technologies developed for the wireless industry aren’t adaptable “because of fundamental differences between wireless and Internet networks,” it said.
VoIP providers offer “robust” E-911 service to nearly all customers, based on their registered addresses, Verizon said. It would be a shame if VoIP services, which worked well in the aftermath of Hurricane Katrina, could not be offered to the public “simply because they were not capable of providing automatic location information on 911 calls,” Verizon said. As long as nomadic customers update their locations when they move, “the location information provided to PSAPs is equivalent to that provided by traditional circuit-switched telecommunications providers,” Verizon said.
“Imposing such a mandate despite the impossibility of compliance would have a predictable and highly negative effect,” the VON Coalition said. “Rather than benefit public safety entities, an autolocation mandate would chill innovation and, in many instances, leave PSAPs with less accurate information than they receive under the existing rules,” the coalition said. “The record confirms there is no existing commercially-ready technology that would allow interconnected VoIP service providers to meet the E911 autolocation accuracy requirement proposed by the Commission,” it said. A few vendors claim to have technologies that could meet wireless standards, “but each of these proposed solutions has serious failings.”
Commenters urged the FCC to set up an advisory group to recommend candidate technologies. In a joint filing, The Center for Democracy & Technology and the Electronic Frontier Foundation said they “strongly agree” but urged the FCC not to forget to include public representatives on such a panel. “A working group composed of all stakeholders, including industry, consumer, technology provider, public safety and privacy representatives, provides the best means of identifying potential solutions and evaluating these approaches using a broad range of real-world deployment scenarios,” Vonage said.
Just don’t hold underlying broadband networks responsible for developing the E-911 location solution, as Vonage wants, the NCTA said. The FCC “should reject Vonage’s attempt to shift responsibility for E911 compliance to the underlying network provider,” the association said. It’s “premature for the Commission to assume that the ability to automatically locate a caller will rest solely with the broadband Internet provider.”
Vonage again called for networks to handle the job. The commission should support “efforts to develop network- endpoint based autolocation solutions” because they “offer the most promise,” Vonage said. Network-based solutions “provide the degree of precision public safety expects and are available wherever a user can access a broadband network,” it said. But Vonage agreed with the NCTA that the FCC should hold off on a mandate. “As interconnected VoIP services have continued to evolve, so too have potential autolocation capabilities,” said Vonage. “The Commission should allow ample time for these solutions to be identified, finalized and implemented.”