I take it all back. Forget the “quacks like a duck” test for emergency service calling regulations and VoIP. Here’s my mark II version. If you sell VoIP interconnected to the PSTN together with connectivity, you’re liable for E911. Otherwise, you’re not. The sale doesn’t need to be a bundle; merely by entities with substantially similar control or billed through one entity. So SkypeOut wouldn’t be liable for E911, unless it was being done on one of their WiFi hotspot partners, in which case they’re supplying the bit haulage too and damn well ought to know where you are and how to route your call.
Any better ideas?
Posted by Martin Geddes at 02:11 PMTrackBack URL for this entry:
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At ISPCON, Jason Talley of Nuvio pointed out that many VoIP purchasers buy nomadic service -- take your phone number with you when you travel -- and that any 911 requirement combats a feature that only VoIP can provide.
Posted by: at December 2, 2005 02:55 PMThere's no logic to requiring vertically integrated providers to do something that other providers are excused from. All you're doing is putting your thumb on the competition scale.
Any obligation should be based on contractual commitments to subscribers. If regulators feel absolutely compelled to get involved, let them define the language that subscribers must agree to for a service that comes without emergency calling. Then if third parties sue when they pick up someone else's phone and fail to reach emergency services, let the courts figure out who's liable. They can say: no one, or the subscriber, or the service provider. After a couple of cases are decided, the market will shake out.
Soon enough, I am hoping, we can communicate with E911 operators via voice and other forms of communications. As such, E911 requirement should be placed on the access providers alone. We should interpret E911 requirement in PSTN to be placed not on voice service provider, but access provider to PSTN. This is analogous to us getting E911 service even on a fax or data line.
Posted by: at December 2, 2005 07:45 PM999 is/should be a simple, no-infrastructure yell button...more like VHF 121.5MHz than VoIP. IN fact, you could do that..
Posted by: at December 5, 2005 02:03 PMYes, I have a better idea. Emergency service (911, 112, 999 etc.) should NOT be regarded as an integral part of the voice service. It is a separate LOCAL service, there is NO point in my dutch telephony provider to offer me emergency calls while I am in France. It is a service that should be provided by my local french access provider. Back in January I put a proposal to that effect into ETSI (see http://www.eemvalley.com/Mambo/content/view/9//) but it was received lukewarm and I did not push it further.
This does put the requirement on the terminal/handset to provide this service separately to the end-user. Possibly "hidden" behind the phone number 112 in the telephony client...
Posted by: at December 8, 2005 09:16 AM