more on E911 with no Opt Out?

[David Farber <dave () farber net>]

Begin forwarded message:

From: Ed Biebel <edward () biebel net>
Date: June 7, 2005 1:30:24 AM EDT
To: 'Bob Frankston' <Bob19-0501 () bobf frankston com>, 'Bob Frankston'  
<Bob2-19-0501 () bobf frankston com>, dave () farber net, 'Ip ip'  
<ip () v2 listbox com>
Subject: RE: [IP] more on E911 with no Opt Out?


My argument is not about how it is funded or the rigid protocols  
surrounding
E911.  Those have to do with specifics of delivery which I  
acknowledge need
improvement.

The central theme of my message is that non-wired communications have a
difficulty in providing precise location information to emergency
responders.  This information is no longer an optional piece of data in
delivery of emergency service.  The reality of the situation is that
non-traditional communications services must solve this problem and  
time is
running out for them to do so.

Beyond the regulations that may be enacted to require it, other market
pressures will force them to solve it.  In Philadelphia, a lawsuit  
was filed
challenging that a slow response time to a patient resulted in their  
death.
Those of us in EMS have been expecting a lawsuit such as this for  
some time.
As medical field care has improved, more and more illness can treated  
with
fast response.  Some strokes which years ago were simply observed can be
treated if a person reaches a medical facility within the first three  
hours.
Slow response is moving into the realm of malpractice.  Similar  
issues have
developed for police and fire.  Emergency services have responded by  
doing
what we do well: documenting.  Several years ago, we started noting  
on our
patient care reports "factors affecting care".  Poor location  
information is
a common culprit and is being well-documented.

So to me, the need to solve the location issue with wireless  
communications
is inevitable.  If the regulators don't solve it and the companies
themselves don't solve it, it will only be a matter of time before the
courts will.  Someone will file a lawsuit challenging Skpe's failure to
provide a good location lead to a treatable medical problem going  
untreated.
E911 may not be the answer but it is a liability to wireless because it
exists and has set that bar such that location information is a  
requirement.

-----Original Message-----
From: Bob Frankston [mailto:Bob19-0501 () bobf frankston com]
Sent: Monday, June 06, 2005 6:37 PM
To: 'Ed Biebel'; 'Bob Frankston'; dave () farber net; 'Ip ip'
Subject: RE: [IP] more on E911 with no Opt Out?

I wrote a series of essays on this with
http://www.frankston.com/public/writing.asp?name=vvt being an intro so I
don't want to repeat all the points.

E911 is rigidly defined. A set of protocols and interfaces could do  
far more
and deliver a better service. If people care about E911 then  
marketing the
capability would give an advantage. Funding it through phone calls, as I
keep pointing out, is strange. It's just a public utility and should be
independent of the use of legacy technologies.

You're arguments amounts to saying that email should be charged 35¢ a
message in order to fund the postal system. What is the path of  
"reasoning"
that leads from saving me from heart attacks to making VoIP immoral?

-----Original Message-----
From: Ed Biebel [mailto:edward () biebel net]
Sent: Monday, June 06, 2005 18:05
To: 'Bob Frankston'; dave () farber net; 'Ip ip'
Subject: RE: [IP] more on E911 with no Opt Out?

I think there is a certain amount of truth in the fact that our  
government
policy holders have difficulty wrapping their hands around new  
technology
and how to implement it.

However, I still think that the two separate issues are intertwined.   
The
government is involved because it has responsibility for providing the
emergency services or at least the front-end call taking for the  
dispatch
process.  They have set the standard of what data is needed to do that
properly.  To streamline the access and delivery of those services, they
provide access to a common gateway called E911.  There are other ways to
access the system (local numbers, a telephone company operator, etc.)  
but if
your device claims to allow users the ability to access the E911  
gateway,
you agree to provide a common set of data as part of the package -- in
addition to the call, you have to provide accurate location information.

The problem with the wireless and other technologies, is that they  
want to
tell their users (or their users expect it because the device they  
use looks
just like a wired phone and behaves just like a wired phone) that  
they can
access the E911 system but they don't want to bear any responsibility  
for
providing the agreed upon set of data to the gateway (E911).  The  
RBOCs have
to provide location information and undoubtedly had to modify their  
system
to do so.

I maintain a single inexpensive landline in my home because I know that
reliable access to E911 is not a feature on my wireless service  
(despite the
fact my provider markets their phones in part by showing their value in
summoning help) and that feature is important to me.  Adding the  
ability to
access E911 may add cost to these non-traditional systems or make them
non-viable.  But if we truly allow a market-driven approach, is it  
fair to
allow one system to bear the cost of providing a full data set to the
emergency gateway and another system to be exempt from the cost?

Other companies have worked around this obstacle successfully.  My alarm
company, because of where they choose to locate their office, cannot  
contact
my local PSAP via 9-1-1.  They negotiated a system of accessing the PSAP
through a 7 digit number and provide a human operator to provide  
accurate
location information to the PSAP.

As technology expands, the concept of what constitutes a telephone  
will give
way to a broader understanding of a communications device.  But that  
doesn't
mean that concepts such as E911 go away because a precise and accurate
location is a fundamental part of the required data set in providing
emergency service.  Perhaps E911 will evolve into an emergency access
gateway that you can access with any manner of communications  
device.  This
"emergency access gateway" will always require that devices sending  
messages
to that gateway will have to provide a current location in the data set
because without location, you cannot provide the service.

-Ed




-----Original Message-----
From: Bob Frankston [mailto:Bob2-19-0501 () bobf frankston com]
Sent: Monday, June 06, 2005 4:25 PM
To: dave () farber net; 'Ip ip'
Cc: 'Ed Biebel'
Subject: RE: [IP] more on E911 with no Opt Out?

E911 is a good example of the problems we face in policy. It's a  
wonderful
sound bite -- saving lives and great TV. But the implementation model  
shows
an inability to understand the concepts that define the Internet and the
marketplace processes that drive it (and evolution).

I've already written about how we could do far better by recognizing
supporting a process that allows technology and services to evolve. I
focused on the no-opt-out aspect to emphasize the price of stifling
paternalism. It's akin to banning FedEx because it disrupts a funding  
model
used to hide subsidies to the postal system.

It's not about privacy -- being able to choose to do better and to  
trust me
-- must all phones be E911 phones? What does that even mean?

Again, we have politics trumping reality. Robert Laughlin's A Different
Universe goes far further in demonstrating the fallaciousness of this  
way of
thinking -- not just in politics but within the scientific community  
itself.
While I don't agree with all his comments about business it should be on
your required reading list. I'm trying to list such books at
http://www.frankston.com/?Name=Books though it's only a start.


-----Original Message-----
From: owner-ip () v2 listbox com [mailto:owner-ip () v2 listbox com] On  
Behalf Of
David Farber
Sent: Monday, June 06, 2005 14:34
To: Ip ip
Subject: [IP] more on E911 with no Opt Out?



Begin forwarded message:

From: Ed Biebel <edward () biebel net>
Date: June 6, 2005 2:17:41 PM EDT
To: dave () farber net
Subject: RE: [IP] E911 with no Opt Out?


I think there are two issues here that are intertwined that should be
separated.

1.  Is E911 a good thing?
2.  Is the approach the FCC is taking to implementing E911 for
telecommunications other traditional hard-wired telephone services
correct?

With respect to #1, as Emergency Services provider, I think E911 is a
very
good thing.  E911 solved for us a critical problem, the fact that in an
emergency, people do not think clearly and frequently provide incorrect
information which results in people getting hurt or dying.  These
situations
run the gamut from a child calling and giving their home address to a
dispatcher instead of grandma's house (who is watching them) to
motorists
who are lost and could not even give the town from which they are
calling
let alone a precise location.

As any emergency provider will tell you, with wireless phones replacing
landlines this problem has again been increasing.  I can tell you
that even
on interstates that provide easy references points (markers every
tenth of a
mile with only two directions of travel) that I have been dispatched to
locations that are *miles* from where the actual incident is located.  .
You can't rely on the dispatchers to know the addresses in their area
because of 911 routing.  When our PSAP becomes overwhelmed, the calls
bounce
to the PSAP in the next county.  This puts the lives of crews and the
public
in danger. The public receives a delay in care and the emergency
responders
jeopardize their lives responding to non-existent calls because of poor
location information.

Yes we do sacrifice some privacy but there is a great good from the
sacrifice.  As well, many agencies provide an "opt-out" in the form of a
7-digit traditional number which can be caller-id blocked but still
allow
you to contact help.

In terms of #2, I think the implementation of E911 for the new
technologies
is what is lacking.  The FCC has not caught up with the concept of a
telephone not having a fixed physical location any more.  GPS has helped
this somewhat with wireless (GPS does not work indoors where it is
used by
many as the primary telephone) but is not a panacea.  In order to
keep the
public and our emergency responders safe a method of determining a good
"right now" location that reflects "locationless-ness" of new
technologies
has to be developed.  The industry owes it to the public to help
accomplish
this.

-Ed


-----Original Message-----
From: owner-ip () v2 listbox com [mailto:owner-ip () v2 listbox com] On
Behalf Of
David Farber
Sent: Monday, June 06, 2005 12:32 PM
To: Ip ip
Subject: [IP] E911 with no Opt Out?



Begin forwarded message:

From: Bob Frankston <Bob19-0501 () bobf frankston com>
Date: June 6, 2005 12:14:41 PM EDT
To: David Farber <dave () farber net>
Subject: E911 with no Opt Out?


According to the latest FCC release



"Begin maintaining a "Registered Location" for every customer - no
opt-out allowed -that may be modified by consumers by multiple means,
including use of the telephone;"



I wonder what this means. Also what does it mean to attempt to impose
E911 on Skype-Out. All of this assumes there is a physical device
called a "telephone". It's as if we attempted to regulate email by
requiring stickers on "e-mail-boxes".



Perhaps it's like the attempts to pass laws requiring having someone
walk along with every automobile warning horses to get out of the way.



Bob Frankston http://www.frankston.com





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