I've just read FCC Chair Kevin Martin's statement about today's FCC dictate requiring that VoIP providers offer E911 services starting 120 days from now.
Already, the mainstream news media are painting this as an airtight provision that solves the problem of E911 access. Yet I must tell you, it is anything but airtight.
The customer must provide the location information of their callback number, and the VoIP provider must provide the customer a means of updating this information.
1. People move. People get harried. People forget. Will VoIP providers hit existing customers over the head - say in their monthly online or mailed invoices, to keep this information current?
The FCC is not "dictating (any) technical means" to enable this in 120 days. So, in order to make the deadline, Martin says, "VoIP providers may interconnect directly with the incumbent LEC's 911 network or purchase access to this network from competitive carriers and other third-party providers."
2. Whoa, trouble. Even if the LECs open the door to all comers, do they have the infrastructure in place to enable all requests within 120 days?
3. And what about those companies who are told to take a number and wait in line? Yes, they can "purchase access," but what about start-ups who are insufficiently capitalized? Will this result in a thinning of the herd?
4. As I've said before, will either the major or less-known VoIP services pass on the costs of E911 gear-up, access and maintenance to subscribers by means of either overt nickel-and-dime, or hidden fees buried in an incremental rate increase for which other causes are given?
Martin writes: "While the rules we adopt today are a step in the right direction our actions today are not the end of the story. An advanced 911 solution needs to be developed that enables VoIP providers to locate their customers automatically much like wireless providers are able to locate their customers today."
5. He's talking about "nomadic VoIP." You VoIP 911 from another computer, or from your own computer you've taken with you. You are having a stroke. Maybe you don't know your current location... in some hotel, in some coffee shop, but what's that address? You don't have the faculties to ask. What then? In a post I made earlier today, I quote the guy who oversaw the FCC's successful effort to implement nomadic VoIP for cell phones. He says that doing so for IP telephony won't be easy. Says it will take years, not months.
Finally, as our Ben Charny notes, we are not sure about how this ruling will affect softphone-only VoIP providers such as Skype.
6. OK, Skype, wassup? Ben notes: "Skype said it is 'working with the FCC to develop appropriate emergency response solutions for IP-based communications services.'" Yet, as I noted earlier today, EnterpriseVoIPPlanet.com has a copy of a note Skype wrote to the FCC essentially wanting out of this dictate.
7. And if Skype wants out, what about all the other softphone providers?
Do you have questions about this ruling? You can pose them in a TalkBack.