yet more on FCC VoIP 911 order

[David Farber <dave () farber net>]

Begin forwarded message:

From: DV Henkel-Wallace <gumby () henkel-wallace org>
Date: May 22, 2005 11:07:35 PM EDT
To: Brad Templeton <btm () templetons com>, John Levine  
<johnl () taugh com>, "Steven M. Bellovin" <smb () cs columbia edu>
Cc: N3jmm () aol com, David Farber <dave () farber net>
Subject: yet more on FCC VoIP 911 order


The point, and risk, of the FCCs order (technically not a "law" I  
believe BTW) is that it injects mandatory policy on how the network  
is operated.  The two key words are "mandatory" and "operate."

As scientists or technologists we can argue all we want about corner  
cases and existing mechanisms.  Those things are generally irrelevant  
to the law.  I don't mean this as a slur; it's legal scholars who use  
the phrase "the law is an ass."  The FCC, like most rulemaking and  
lawmaking bodies, is at its best when aiming for a particular outcome  
in the aggregate.

Thus John Levine's comment that requiring certain behavior from DHCP  
implementations "could probably work well enough to be useful" is  
right on target.  E911 isn't that great, but it's OK in many cases,  
and that's all that was intended.  (I doubt his claim of cost  
requirements is of the slightest interest to the Commission).

Bellovin wrote to me to say that none of this matters because the  
ILECs won't cooperate.  The FCC press release specifically called  
this case out with following language (check out the last sentence in  
particular -- it's what the ILECs hate to hear):

> The incumbent LECs are required to provide access to their E911  
> networks to any requesting telecommunications carrier.  They must  
> continue to provide access to trunks, selective routers, and E911  
> databases to competing carriers.  The Commission will closely  
> monitor this obligation.

Templeton wrote to me directly to say that the mechanism need not be  
mandatory; the existing UI would still suffice.   But check out the  
following language from the FCC:


> Finally, the Commission stated its intention to adopt, in a future  
> order, an advanced E911 solution that includes a method for  
> determining the customer’s location without the customer having to  
> self report this information.

So: the real problems remain:

1> The FCC is basically mandating how a protocol (VoIP) should look  
-- and in fact they're mandating more since the infrastructure to  
support it must be modified: not just at the carrier end but in the  
installed base (i.e. DHCP client data will have to have an API so  
that VoIP software can pick it up and use it.  None of this would  
preclude companies who implement their own DHCP infrastructure just  
as they do with PBX mechanisms.  But Windows and MacOS would have to  
be patched to make this happen.  _This_ is a shift in powers.

2> Just as with E911, does anyone seriously believe that this  
information won't be abused?  In no time it will be picked up by web  
browsers and passed back to the server so that the "right" ad can be  
generated or the proper filtering be supported (sorry, no liquor ads  
in dry counties), not to mention other generalized tracking.  Hell,  
the *IAA will be able to use it to help enforce region coding and the  
phasing of releases for different markets.

It's these two points that are the real problems with this proposal.

-d



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