Telepocalypse

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Today’s best discussion on Slashdot is about how VoIP providers of PSTN interconnect may be regulated by the FCC to mandate emergency service (“911”) capability. There an excellent article at Voxilla from last December on 911 regulation that covers a lot of the same ground.

I’m going to argue the unexpected, and say that 911 service should be a mandatory regulated feature. But with a major twist I’ll leave until the end.

911 service is not a normal market product. The service that is summoned is provided through a compulsory levy on local businesses and residents. The fire brigade don’t ask for a credit card before turning the hoses onto your burning house. And if the caller is the beneficiary, you may be in no state to engage in any form of usual market interaction. The service always requires urgent response; there is no time to discover how the service should be accessed, or evaluate competing actions. When lives are on the line, you shouldn’t be reaching for the yellow pages.

The beneficiary of the service is often either not the caller or owner of the telephone line. There is an externality in choosing not to have 911 service; other people suffer without having a choice of exercising the market mechanism. If my babysitter has a heart attack, and I don’t have 911 service, some innocent third party suffers. It’s not reasonable for babysitters to have to inquire about the 911 service my telephone is attached to, because the heart attack cannot be reasonably foreseen. If my house burns down and takes the rest of the neighborhood with it, other people suffered for my parsimony. If I see the burglar breaking into the house opposite, but can’t call the police, more heartache.

Users are also mobile, and are not realistically able to create a personal comunications safety bubble around themselves. You’re dependent on other people having the service for when you get in trouble. You can’t escape the externality by being richer and buying better service. If you’re lying at the side of the road unconscious, the good samaritan passer-by isn’t going to frisk you down to see if you carry the thousand dollar Hypersafe Satphone™. At the point of use, there is a market failure. Market failures require regulation.

Externalities like pollution, health injury, or social damage call for regulation. By definition, they are at best addressed through indirect secondary market mechanisms like emissions trading to rebalance the costs more fairly. It’s hard to imagine such a system for a personal service like emergency calls. How do you provide financial incentives for everyone to adopt 911 service via market mechanisms? It just doesn’t fly.

The fire brigade or police department will effectively ask for a credit card for a business property that has repeated false alarms. So there is a degree of market encroachment. Abuse of service can be punished through quasi-market mechanisms. The capitalistic instinct to provide truly enhanced emergency response should also be encouraged. Burglar alarms and monitoring systems for the elderly and infirm are existing examples built atop the PSTN. Niche markets should develop their own enhanced response systems. Maybe epileptics will carry special equipment that monitors their wellbeing, calls for help, and uses a loudspeaker to advise passers-by what to do if the owner has a seizure. But society needs a baseline; a reasonable expectation of emergency response wherever you are, catering to the needs of the ordinary person.

So I hope you’ll agree with me by now, we need regulation. The only question is to what ends and how to achieve them.

The end-to-end principle tries to separate service from connectivity. Normally, that’s a laudable aim. In this one case, however, it’s the opposite of what you need. I might take my Vonage service on the road, and plug into a high-speed line in a hotel in Paris. If I have a medical emergency, I want to get a Parisian ambulance to come and take me to a Parisian hostpital. Au secours! I don’t want to speak to someone in the emergency response center in Overland Park, Kansas, no matter how nice, upstanding and midwestern they are. I want the service to be associated with the connectivity.

So here is what I propose. We don’t break the basic end-to-end nature of the Internet. But we regulate the provision of public Internet connectivity. We insist that basic IP voice 911 service is always included. Maybe we reserve a private IP address (168.9.1.1?) as the default route. It isn’t hard. If we’re feeling fancy, we include a default route to a WSDL directory to discover additional enhanced emergency services on offer. (Yes, I’d like to connect to a parlez-vous Anglais operator in that Parisian hotel room.)

Whether I’m wardriving around, sat in my hotel room, or feet up at home, the service is always there. We don’t yet have massive dynamic meshes of roaming users, and probably won’t for another decade or two. The end points of the Internet are always physical and fixed, to a reasonable approximation (i.e. at most one hop away to a cell tower). Paid-for Internet connectivity is always a hop away. Payments require a legal framework for commerce. Those contacts are regulatable. Taxing VoIP service providers and forcing 911 provision just doesn’t work, because the service will just move offshore. Connectivity can’t move offshore. Call it the revenge of geography. I want the ambulance to arrive at my very physical door, not my extremely virtual IP address. IP addresses and end-to-end are just abstractions. A heart attack isn’t.