In article <telecom24.130.6@telecom-digest.org>,
<hancock4@bbs.cpcn.com> wrote:
> Thor Lancelot Simon wrote:
>> *If* Vonage were willing to pay the same fees other local exchange
>> carriers pay for 911 connectivity *in each LATA*, *then* Vonage could
>> route 911 calls correctly. Avoiding this *cost* has been a major
>> competitive win for Vonage all along and it is hard to not see it as
>> a major reason, if not _the_ reason, why Vonage has fought state
>> regulation as a local exchange carrier: by avoiding regulatory mandates
>> like 911 service standards Vonage avoids the cost of compliance.
> Excellent points.
> The states in my area allow a 911 fee to be tacked on to phone
> bills. The money goes to the run the 911 call centers.
It's not just that. To actually do the interconnection, Vonage would
need to build some infrastructure: they'd need trunks into every LATA
in which they offered 911. A responsible telco would, it seems to me,
see this as an unavoidable part of the cost of offering a service for
emergencies reachable by dialing 9-1-1, because you basically can't
give callers the same user interaction they expect in an emergency if
you *don't* have those trunks. Packet8 is an example of a VoIP telco
that is responsible and does the right thing: they *don't* offer a
service that works in an unexpected and dangerous way when the user
dials 9-1-1; they *do* offer genuine 911 service -- enhanced 911,
even, though I have to question whether this is desirable, because
of the low quality of the location information for VoIP -- everywhere
they have managed to run trunks to. They charge their users separately
for this service; we can argue about whether it should be a mandated
service or not but it certainly seems equitable to charge for it if it
is not mandated, and that's what they do.
What Vonage does is provice fake 911 service that may be adequate for
many callers much of the time, but emergencies by defintion are not
"many/much" situations: they are emergencies; they are exceptions.
And for callers in some areas, the service is worse than inadequate,
it actually makes emergencies worse, by wasting the caller's and the
emergency personnel's time by sending the calls somewhere that cannot
handle them at all.
Thor Lancelot Simon tls@rek.tjls.com
"The inconsistency is startling, though admittedly, if consistency
is to be abandoned or transcended, there is no problem." - Noam Chomsky