Commentary from The Jeff Pulver Blog:
http://192.246.69.231/jeff/personal/index.html
April 27, 2005
'Help! I Need Somebody!'... But do we really need Somebody to
Micromanage Emergency Response Solutions for IP-Based Communications?
Last night I read with some concern several news accounts of a comment
FCC Chairman Martin made yesterday regarding application of emergency
response obligations on VoIP service providers.
Now, to be clear, I have no problem with the adoption of
appropriately-tailored rules establishing guidelines for
implementation of an emergency response system for IP-based
communications providers. Who could argue with the promotion of such a
public good? As I've said repeatedly, IP technology will allow for the
establishment of next-generation emergency response capabilities that
will dwarf anything we currently see on traditional telecom networks.
In fact, the Global IP Alliance, which I helped to found, is now
taking the lead to develop a global IP-based Emergency Response
System. It is my hope that this global effort will allow users to hit
a single button and immediately activate appropriate language
translations, notify appropriate points of contact and emergency
responders, transmit individualized medical histories and special
circumstances, etc.
New rules designed in such a way so as not to disrupt new technology
and services but ensure the public good should be acceptable to both
industry and government. Cookie-cutter application of old rules to
IP-based communications, however, could tend to stifle new technology
and innovation and interfere with the ability of IP-based
communications providers to develop superior emergency response
systems.
My preference of course is that industry take the lead to develop
non-proprietary emergency response systems that are most suitable to
promotion of IP technology while promoting the broadest public
good. Short of that, I would hope that regulators, as they inject
their authority over IP-based communications, look at IP technology
with a fresh eye and an understanding of the differences between
IP-based communications and traditional telecom networks.
One area where I think it is appropriate for government intervention
would be to ensure that unaffiliated IP-based communications providers
have access to the "selective routers" and other infrastructure
currently controlled largely by incumbent carriers. I would hate to
think that those that control necessary infrastructure could stand in
the way of establishment of a workable emergency response capability
by IP-based communications providers. Certainly, lives should not be
lost so that certain providers might be able to maintain a competitive
advantage or point to the inadequate capabilities of unaffiliated
IP-based communications providers.
Another area for government oversight would be to ensure that PSAPs do
not block the use of administrative access lines for nomadic emergency
response services. These administrative access lines provide a
critical interim solution while the IP-based communications industry
moves forward rapidly to develop the technological means for the
provision of emergency services to nomadic end users.
I'm curious to see the fruits of Chairman Martin's statement and I
trust that he will not simply "react" to current fears as he and his
colleagues weigh in on emergency response solutions that might
implicate IP-based communications. Any regulator involvement must
continue to promote innovation and advance the promise of IP-based
communications while simultaneously promoting the public good and
allowing IP technology to improve emergency response solutions.
Jack Decker (jack-yahoogroups@withheld_on_request)