The Restrictive Future
The FCC knows that the self-reporting regime is inadequate and has already issued a warning that there is a next generation. The press release adds that "the Commission stated its intention to adopt, in a future order, an advanced E911 solution that includes a method for determining the customers location without the customer having to self report this information." This "self-location" capability is, at first glance, an impossibility for VOIP. At a TCP/IP level, location is an unknown piece of data, and divorcing address from physical location was a major goal of the protocol. Imagine the problems that tunneling and mobile connectivity (such as mobile WiMax, once it comes out) would present.For any of this to work, all VOIP hardware would have to be upgraded to new, undoubtedly more expensive hardware and all the software revved to support location identification protocols. Its a bigger mess than the self-reporting disaster. The only alternative, and what I assume will actually happen, is the end of nomadic services. VOIP vendors will have to find a way to confirm that the customer is using the service at a particular location and require him to keep it there. My service is through my Internet service provider, Speakeasy.net, a DSL provider. Compared with other VOIP providers, Speakeasy has been highly restrictive in its terms, and Im convinced this was forward-looking of it. When I got my Speakeasy Voice service, the first thing I did was test the 911 service. First I called the local police and asked them if I could test 911 without getting in trouble. The officer told me that 911 calls rang right at his station and that I should try it. I called 911 and the same officer picked up and read me back my name, number and address. This is essentially the capability ordered by the FCC. (Even though the behavior at my home appears to conform with the FCC order, the Speakeasy Voice Service Subscriber Agreement indicates that Speakeasy does not have real 911 or E911. This, the company claims, is just lawyer talk and it in fact does have full E911 on its network.) Speakeasy service is different from most VOIP vendors service in that it knows, pretty much with absolute certainty, the physical location of the telephone making a call. Since it only sells its service to its DSL customers, and it knows the location of the phone line on which the circuit is provisioned, and its VOIP TAs are tied to the static IP address for that circuit, its basically not possible to move the phone line to another location. This point is critical. As best as I can tell, VOIP services provided by cable companies are in a similar position, or at least they have the capability to tie their users to a specific location. Speakeasys VOIP service is actually provided by Level3, which is a customer of Intrado (whose stock not surprisingly spiked on the news of the FCC order), a company that provides 911 delivery services to VOIP companies. Companies like Intrado and the HBF Group allow ILECs to not have to deal with every VOIP provider and VOIP providers to not have to deal directly with the ILECs, since access to the 911 network goes through the ILECs. Intrado also solves certain other problems that VOIP presents to the 911 system, such as its natural inability to handle calls for numbers outside of what is called the rate center, meaning the geographic region in which the PSAP (Public Safety Answering Point)the emergency call center where the 911 call goesis located. Many VOIP providers will let you get a phone number, for example, with a Miami area code even though you live in Milwaukee. The idea that Internet services should be left alone lest the sky falls has clearly lost in the FCC, and the standards for VOIP 911 service will be very high from now on. That doesnt mean the order will produce an appreciably better situation. It seems to me that if customers cant be bothered to provide accurate location information its not hard to see the next disaster coming down the road. The self-location solution, even if its really possible (Im skeptical), is still science fiction from the standpoint of today and will be resisted tooth and nail by the industry for cost purposes, and we wont see it for a long time. What we will see is a rollback of many of the features that made VOIP a gee-whiz technology, especially nomadic service. Look for vendors to find ways to be like Speakeasy and restrict their users to one physical location. This will not only comply with the order, but it will be good for their liability position. Security Center Editor Larry Seltzer has worked in and written about the computer industry since 1983. Check out eWEEK.coms for the latest security news, reviews and analysis. And for insights on security coverage around the Web, take a look at eWEEK.com Security Center Editor Larry Seltzers Weblog.
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Looking at a hardware solution, even if one were to mandate GPS, it doesnt work well inside buildings and doesnt provide altitude information (what if I call 911 from the 50th floor of the Empire State Building?). I am told by industry people who should know that there are credible efforts to develop technology, perhaps with GPS assisted by other technologies that work where GPS is weak. Undoubtedly these developers have spoken to the FCC and have gotten a semi-official blessing.