The Implications of the

By Larry Seltzer  |  Posted 2005-05-22 Print this article Print

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.
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 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:
  • 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.
And it doesnt stop there. What if someone steals the users TA, takes it across town and makes crank 911 calls? Its going to happen, and the victim of that next call that the police didnt get to because of the crank call will sue the VOIP provider and testify before the FCC.

There are companies in even more precarious positions than Vonage. The FCC says that the order applies "... to companies that provide phone service that allows customers to make and receive calls on the PSTN ..." but its not clear to me if the "and" is strict like it would be in programming. For example, users of SkypeOut can make calls out using the PSTN, but not receive them. I suspect the rule would apply though. Commissioner Michael J. Copps added: "Critically, we limit our requirements here to services that are capable of origination and termination on the public-switched network. This means they are directed squarely at substitutes for basic telephony. Our rules govern the kind of services that a parent or child or babysitter or co-worker will justifiably expect to work in a 911 emergency situation."

Unfortunately, from a public safety standpoint, the ability to call the 911 caller back is critical, and here SkypeOut is problematic. One wonders if the FCC will find SkypeOut to be incapable of complying with the order and inherently unsafe.

Next page: The restrictive future.

Larry Seltzer has been writing software for and English about computers ever since—,much to his own amazement—,he graduated from the University of Pennsylvania in 1983.

He was one of the authors of NPL and NPL-R, fourth-generation languages for microcomputers by the now-defunct DeskTop Software Corporation. (Larry is sad to find absolutely no hits on any of these +products on Google.) His work at Desktop Software included programming the UCSD p-System, a virtual machine-based operating system with portable binaries that pre-dated Java by more than 10 years.

For several years, he wrote corporate software for Mathematica Policy Research (they're still in business!) and Chase Econometrics (not so lucky) before being forcibly thrown into the consulting market. He bummed around the Philadelphia consulting and contract-programming scenes for a year or two before taking a job at NSTL (National Software Testing Labs) developing product tests and managing contract testing for the computer industry, governments and publication.

In 1991 Larry moved to Massachusetts to become Technical Director of PC Week Labs (now eWeek Labs). He moved within Ziff Davis to New York in 1994 to run testing at Windows Sources. In 1995, he became Technical Director for Internet product testing at PC Magazine and stayed there till 1998.

Since then, he has been writing for numerous other publications, including Fortune Small Business, Windows 2000 Magazine (now Windows and .NET Magazine), ZDNet and Sam Whitmore's Media Survey.

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