TELECOM Digest OnLine - Sorted: Blasts FCC E911 Order for Discouraging Innovation Blasts FCC E911 Order for Discouraging Innovation

Jack Decker (jack-yahoogroups@withheld_on_request)
Thu, 19 May 2005 14:29:30 -0400 Blasts FCC E911 Order for Discouraging Innovation and
Hampering Long-Term Emergency Response Capabilities

Leading Industry Thought Leader Urges FCC to Ensure America's Role as
the World Leader in Innovation, Communications and the Internet

MELVILLE, New York, May 19 /PRNewswire/ -- The following quotes
may be attributed to Jeff Pulver, CEO of in response to the
FCC's adoption of an order imposing E911 obligations on VoIP providers
within 120 days:

The FCC Order is, no doubt, motivated by the most noble of goals
-- reliable emergency response systems for all Americans. No one
wants, or is pushing harder to implement these services, more than the
VoIP industry itself. Most PSTN-connected VoIP providers currently
provision at least basic 911 emergency services, and typically
provision E911 for fixed locations. If the FCC Order, in fact,
compels VoIP providers to offer technologically impossible enhanced
911 obligations within 120 days of the Order's effective date, I fear
the Order could put more Americans in harms way by denying consumers
access to useful VoIP services and, in the process, could have
detrimental consequences on the emerging IP-based communications
industry, at least the smaller VoIP providers who cannot feasibly
provide a nationwide E911 service within 120 days.

The FCC had a golden opportunity to take one positive steps to
promote IP-based communications. The FCC could have prohibited "port
blocking" and compelled direct access to the ILEC-controlled emergency
response infrastructure. Instead, the FCC chose to regulate the
previously unregulated, and declined to regulate those that it has
obvious authority to regulate -- the traditional telecom carriers. As
it stands, unaffiliated VoIP providers are left to the mercy or
goodwill of their retail rivals -- the telecom carriers that control
access to the emergency response network. The FCC has given
lip-service to its desire to prohibit port blocking and has been
looking for a vehicle to do so. A proceeding fell into its lap, and
the FCC abdicated its responsibility on this issue. IP technology
could allow for functions far beyond the capabilities of traditional
communications networks, but it requires farsighted regulators to look
at the technology with a fresh eye and a commitment not to stifle the
potential and allow innovators to experiment and push the limits of IP

Today, the FCC caved to the shortsighted vision and sacrificed our
long-term emergency response capabilities and America's role as a
leader in communications, the Internet and innovation. I, by no
means, intend to belittle the noble goals behind a ubiquitous E911
solution, just the method by which the regulators intend to drive us
there. I am convinced that IP technology will vastly improve
emergency response capabilities. We all want the best possible
emergency response capabilities to become available to all Americans
-- all the world -- as soon as possible. I, however, do not want to
see E911 used as an immediate tool to bring down the emerging
industry, particularly the most vulnerable start-ups without the
deep-pockets, resources, and political connections. Extending
immediate E911 obligations on the smallest, most vulnerable, but most
innovative IP-based communications providers does no one any good
(except for providing a quick political sound bite). In the end, such
actions might mean that no one will ever see the emergency response
capabilities that IP-based communications working cooperatively with
NENA could have produced.

What seems most bizarre to me is that the regulators don't even
seem willing to give the unaffiliated VoIP providers the minimum set
of tools necessary to accomplish their objective for a guaranteed
nationwide E911 network that would allow anyone, anywhere to pick up
any device, dial 911 and have an emergency responder find that caller.
If regulators tell the industry to provide nationwide E911 for nomadic
VoIP services, without simultaneously compelling fair access by
unaffiliated VoIP providers to selective routers and prohibiting port
blocking, how can they expect us to accomplish their mission? Make
excessive demands on the never-before-regulated and most-vulnerable
new start-ups, but don't dare impose any access obligation on the
traditionally regulated entities, the only ones with the essential

I don't get it. It makes no sense to stifle the nomadic
capability and essentially turn every IP-based communications service
into a fixed line, because the added nomadic capability of an IP-based
service does not avail itself of an immediate, ubiquitous, localized
emergency response solution. Government will have essentially
outlawed a valuable service without having evaluated whether having
extra communications wherever there is an Internet connection could
actually increase the potential that someone's life could be saved in
an emergency. Unaffiliated VoIP providers, even if they had the time,
staff and economic resources to work towards a nationwide solution
would be at the mercy of carriers with whom the VoIP provider would
have to partner in order to establish a nationwide E911 service. The
bottom line is that a nationwide solution does not exist and will not
exist in 120 days. If nomadic VoIP services can operate anywhere
there is a broadband connection, it is impossible for a nomadic VoIP
service provider to be in compliance with our current understanding of
the FCC's likely rule.

VoIP, by its very nature, should empower a user to take her
service anywhere without having to check with the VoIP provider to
verify that the particular remote location has an arrangement with the
VoIP provider. It is one thing to compel a primary fixed-line
provider, be it VoIP or traditional telephony, to provide E911
capabilities, but what logic would be served from turning off the
nomadic capability of IP technology simply because the user cannot
access a local emergency response system when she attaches her
computer with a softphone program or other IP phone to a broadband
connection at a hotel or other remote location? Isn't it possible
that a person at a Starbucks who witnesses an armed robbery and
shooting might be able to save a life by being able to either dial the
police or dial basic 911 using her nomadic VoIP solution rather than
preventing any calls because there isn't an E911 capability? Instead
of focusing on the US marketplace, the voice over broadband
entrepreneurs, may instead decide to focus their business activities
in countries that have a more forward looking IP-based communications

Then again, the pending FCC rulemaking may finally be the shot in
the arm the VoIP entrepreneurs need to come forward with communication
services that are not using VoIP as simple replacement or substitute
services, but rather use IP technology to launch new communication
services and applications -- something much truer to the vision of
what an IP-enabled platform promises and not just copycat products or
services. Admittedly, the limited communications network we call the
PSTN controls virtually every communications consumer out there.
There was once a time when the stagecoach controlled most of the
transcontinental traffic. Some day, perhaps now even sooner than some
anticipated, the wireline PSTN will be relegated to be little more
than a minor, single-lane off-ramp on the IP-based network of


Jeff Pulver is the President and CEO of, and one of the
true pioneers of the Internet telephony/VoIP industry. Mr. Pulver is
a globally renowned thought leader, author and entrepreneur. He is
the publisher of The Pulver Report and VON magazine, and creator of
the industry standard Voice on the Net (VON) conferences.
Additionally, Mr. Pulver is the founder of Free World Dialup (FWD),
the VON Coalition, LibreTel, WHP Wireless, pulverinnovations, Digisip,
and is the co-founder of VoIP provider, Vonage. Last year, the FCC
granted Pulver's petition for clarification declaring Free World
Dialup as an unregulated information service. The landmark Pulver
Order was the first decision made by any major regulatory body on IP
communications, and provided important clarification that
computer-to-computer VoIP service is not a telecommunications service.
For more information, please visit .

Contact: Jonathan Askin - 631-961-1049

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