TELECOM Digest OnLine - Sorted: Re: New Technology Poses 911 Peril VOIP Not Part of Emergency

Re: New Technology Poses 911 Peril VOIP Not Part of Emergency
20 Apr 2005 08:51:14 -0700

Jack Decker wrote:

> My commentary follows the excerpts ...

> "If it wasn't the silliest thing, but the hang-up was I couldn't give
> them an exact address, and he was in trouble," said Lawrence, who
> ultimately had to run across Michigan Avenue to the Ypsilanti Fire
> Department before help arrived.

Note that the problem appears to be not knowing one's location rather
than not being able to reach the 911 center. The caller did get
through -- there was a connection. What didn't follow was an address
-- but is that even offered in that area? The capability to transmit
the caller's location to a 911 center and 911 service altogether is
relatively new. It wasn't that long ago you had to provide your
address, and not long ago you had to know a specific 7 digit number
for your local police/fire/ambulance service.

> I will just point out that if a life is ever lost because someone
> cannot reach 911 ...

One of the reasons enhanced 911 was developed was that people in the
suburbs didn't know where there were. Historically, one dialed
0-operator and asked for help. But local operator service centers
have been consolidated and may be many miles away and the operator
won't know the area. Telephone exchanges overlap municipal
boundaries. Also, 911 centers had their own problems.

> Please understand what I am saying here -- if an ILEC is making access
> to the 911 system difficult for VoIP providers because they think it
> gives them a competitive edge, they are creating a condition where
> someone might die, solely to enhance their bottom line.

Actually, the ILEC isn't "creating" anything. It's the VOIP that is
offering something new and different -- marketing as low cost -- and
thus their responsibility to get properly connected.

My county charges a $1/month 911 tax as part of the phone bill. Will
a VOIP provider serving me also charge that fee? I doubt it because
they're exempt from regulation. Seems to me VOIP wants a free ride --
no fee but full service. That's wrong.

The issue of such fees "being wrong" is not relevant here. The fees
exist and everyone has an obligation to pay them.

> ... and are hoping for some type of FCC
> action that will establish a nationwide standard ...

That sounds like [gasp!] telephone regulation to me. We don't
want regulation, do we?

> I again remind you that the foundation for 911 was built while
> the ILEC's were MONOPOLY providers that enjoyed government-protected
> profit margins

I don't believe that is historically accurate. At the time of
divesture and allowance of competition, much of the country did NOT
have any 911 service. What service there was did not have the
sophisticated address transmission feature.

By the time E-911 came along, it was a competitive marketplace with
the appropriate foundations.

Further, I understand that competing wireline local phone companies
don't have any problem with 911 service. It's only VOIP because it
doesn't use the telephone network. I suspect if VOIP had to establish
a physical presence in each central office, like the competing
wireline companies did, it would have full 911 service without any
hassles. But that would be a tremendous expense and raise the
price -- and ruin the whole low-cost attractiveness of VOIP. Again we
see wanting full service but not wanting to pay for it.

As to "govt protected profit margins", that's not true. If it was,
whenever there was a telephone worker strike the company would merely
give in to union's demands, but they didn't. Secondly, other
regulated monopolies like railroads or telegraph companies lost big
money year after year without sympathy from their regulators. If a
phone company had a bad year, it had no guarantee it'd be able to make
that up the following year, as the telegraph carriers found out. The
telephone companies were and are forced to provide many unprofitable
services where they lose big money -- obligations other carriers are
free from. The old Bell System disappeared 20 years ago and can't be
used an excuse anymore. Remember too the old Bell System was strictly
limited in what services and products it could offer-- Bell wasn't
allowed to offer cable TV, for instance. Your statement should have
read "government _limited_ profit margins".

> So now the 911 centers are stuck with technology that only works
> really well with the existing wireline network, and yet nobody in the
> press seems to want to blame the real culprits, which are the ILEC's
> that set up such technologically-mediocre systems, and their
> co-conspirators in local governments who saw an opportunity to bypass
> the voters in the decision making process.

Who says the E911 are "technologically mediocre"? You came along with
something new and you want other people to pick up the cost of using
your product so your product will be cheap.

> No, it's much easier to lay all the blame on the VoIP companies,
> which have only been in business for less than a couple of years (in
> most cases) and who had no say at all into how the existing 911
> system was designed.

You're contradicting yourself. You admit VOIP is something new, yet
you expect the centers to redesign themselves--at their expense--to
accomodate you when you're late.

> [TELECOM Digest Editor's Note: Here in Independence, where we are a
> little more backward in our telecom, it seems, the city has a phone
> in the telecom area which is specifically designated for the job of
> 'emergency, but not 911 equipped calls'. It is not some 'private line
> in a back office somewhere' as seems to be the case in Ypsilanti or
> Brooklyn, NY. The phone terminates in a place where experienced
> professionals can deal with the calls, even though said calls do not
> come through the equipment looking like 'regular' 911 calls. VOIP
> carriers _have to take the word of the various agencies_ that a call
> is being terminated where it can be best handled. Should the VOIP
> carriers have to personally audit each community to assure this?

Yes, the VOIP carriers should personally audit the service everywhere.

That's part of the basic obligation of providing telephone service.
Mr. Decker made a big point of the life-criticial aspect of 911. VOIP
is the service provider to the customer, as such, they have the
obligation to make sure they can connect to someone else as one would
expect. Why should the subscriber have to do it? Almost all
subscribers would have no idea how and where to check.

If I buy a washing machine from a major dept store, they will deliver
it, hook it up, and take it back with a full refund or replace it if
there's any problem. If I buy it from a discount house I'll have to
get it home and hook it up myself, if there's a problem I'm "SOL", but
I've saved $100. Each person makes their own decision as to what's
best for them to buy.

It seems here that VOIP is the discount store, but wants to use --
free of charge -- the dept store's delivery and installation crews
because "the dept store was always there and built up a trade".

You can't have it both ways. When you go to the discount store you
get discount service, pure and simple. VOIP's big selling point is
low price--partly from freedom from regulated prices, partly from not
having the overhead other companies have. That overhead appears to
include the proper connectivity to E911 services (among other

Please don't tell me my 911 tax on my phone bill shouldn't be there.
It IS there and until it goes away, you have no argument. I don't
think it's fair that people like me have to pay this tax while VOIP
comes in, without paying such taxes, and demands a free ride.

As far as VOIP goes, be honest with your customers and tell them
you're running a discount store. You gotta schlep home the washer
yourself, hook it up yourself, and get it serviced yourself. For some
people, that's a great deal. Years ago discount stores made no
pretense of being anything else. Please don't pretend you're a mature
full service company because you're not.

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