The Implications of the
Order"> The FCC hearing included testimony from users who didnt get 911 service on their VOIP calls. In at least some of these cases there was no service because someone didnt bother to sign up for the service. (VOIP providers were not invited to attend.) Until Thursday I just assumed that the user bore some responsibility in these cases, but this was naive. Its clear that the FCC has decided that full E911 service is something that should be expected to work on anything that looks like a telephone. More to the point, vendors like Vonage will no longer be able to let customers use their service until they sign up for 911 and provide a location.The FCC order clearly envisions such a situation, but if Im corporate counsel for a VOIP provider Im still uneasy because its too easy to see how things can go wrong:
Vonage is a good example of another problem the FCC addressed"nomadic services." This is when your VOIP provider allows you to take your TA to some other location (college, a hotel, your office) and use it there while maintaining the phone number from the original location. To get accurate 911 service, the user has to inform the provider of the new location. Its not hard to see how some changes in the network connection, such as a change in subnet, could be taken as a clue to the VOIP provider that the users physical location has changed, and the customer then could be asked to update that information.
- The user could lie and say his location hasnt changed.
- The user could lie and provide an incorrect, but valid address.
- The user could mistakenly provide the wrong address.