Editorial: The FCC's E911 Order: The Shoes Are Beginning to Drop for VoIP Service Providers
Dr. Jerry Lucas
08/01/2005
For the last two years—ever since the VoIP-over-broadband service providers entered the market—we have been saying that their offerings are cheaper only because they don't fully support E911 or CALEA, don't collect taxes or other fees, don't contribute to the Universal Service Fund, and more.
Also, we have been saying the easy ride will be short-lived once the politicians get into the act in response to these VoIP shortcomings. When a state district attorney or other politician can create a 10-second sound bite stating both the VoIP problem and VoIP villain, you will see regulatory or legislative action. A real case in point: A child was dying and the parents dialed 911, but their VoIP service provider couldn't complete the call to the emergency service. The horrifying result was the death of the child.
On May 19, 2005, the FCC brought into its public hearing room some of the victims of E911 call failure, heard their tragic stories and then voted to require all VoIP providers to process E911 calls just as the ILECs and CLECs do: connect the call to the correct Public Safety Access Point (PSAP) and pass along the calling number with the caller's registered location. The order requires that this be accomplished by November 28, 2005. Also, VoIP providers cannot allow their subscribers to opt out of E911. In other words, E911 support is not an option.
In the meantime, it was ordered that by July 28, 2005, all VoIP providers were to notify their existing and new customers of the limitations of their E911 support capabilities. Furthermore, they were mandated to obtain and archive the acknowledgement that the customer has read and understands the limitation notice.
The FCC's order will create havoc for the OSS/BSS folks, but they won't be alone in their VoIP provider organization. The order also requires those providers to send a sticker to be placed near or on the subscriber's phone warning of their E911 call support limitations. What a challenge (or nightmare) for the marketing folks: turn the warning sticker into a customer benefit statement!
The order will have a huge impact on the wireline industry. For example, small VoIP providers will most likely disappear. The financial burden of having to figure out what 911 call support their ILEC offers (E911, 911 or nothing) where the customer resides is not a trivial matter. Other issues include archiving customers' acknowledgements by mail, e-mail or audio recording; paying the E911 service bureau or wholesaler for tapping the ILEC database and interconnection to the PSAPs; and increasing call center support to handle the expected surge in customer calls ("Why doesn't my phone work like it used to, when I plug the adapter into the hotel's ISP services?"). Note: VoIP nomadic phone service has to support E911 like non-nomadic support, and lots more!
The big VoIP-over-DSL providers will likely absorb the financial hit of the FCC's ruling—but what about the marketing impact? Consider that most business customers prefer VoIP-over-broadband not only because of cheap calls in general but also the ability to place and receive calls when they are on the road. E911 support for nomads is very, very challenging, and for many providers not economically viable.
Winners and Losers
The clear losers are the VoIP-over-DSL service providers, and not the cable operators. Note that almost all cable operators don't support nomadic service, and they already have E911 support either in their own infrastructure or through a deal with a wholesaler for E911 processing. So who wins?
Consumers: The FCC was created in 1934 to protect life and property in part through regulation of telecommunications service. For every three Americans there are two E911 calls per year. How can you argue that universal E911 call support is not in the public interest?
PSAPs: Clearly the marketplace is demonstrating that there's more to telecommunications services today than POTS. Some kids don't make phone calls at all—they instant message; disabled citizens are using non-phone communications devices; and more. PSAP infrastructure needs upgrading to address the IP revolution, and likely the FCC's action will be the catalyst for PSAP upgrade funding.
ILECs and CLECs: The established telcos have taken a hit from market share loss to the VoIP providers. The FCC ruling re-levels the playing field to a degree, by requiring all to support E911. In addition, the ILEC position will further strengthen, because you can't place an E911 call without going through an ILEC selective router, and most likely it's dipping their master street address guide (MSAG) database as well. Note: ILECs get compensated for this support service. Also, CLECs have interconnection to ILEC E911 infrastructure that can be wholesaled to VoIP retail service providers. Again, E911 support is a line of business.
What Else Can the FCC Do for VoIP Providers?
Well, the next shoe to fall will be CALEA. Just like most VoIP providers don't support E911, they also fail to support CALEA. A prediction: By September or October, the FCC will invite representatives of law enforcement to appear at a commission hearing (as they did with victims of E911 call processing failures) to speak about missing an opportunity to avert a terrorist attack or other crime because of VoIP CALEA limitations. Their point: If you can't access call detail records or tap criminals' communications, you can't prevent a crime or terrorist attack—let alone make arrests. Following this public briefing, the FCC will no doubt mandate CALEA support by VoIP providers.
If you need to understand Next Generation 911, plan to attend TeleStrategies' VoIP World, which will be held November 1-3, 2005, in Washington, D.C. If you need to understand CALEA mandate technologies and support services, plan to attend TeleStrategies' ISS World, which will be held December 7-9, 2005, also in Washington, D.C. For conference agenda information and to register, please go to www.telestrategies.com.
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