more on FCC VoIP 911 order

[David Farber <dave () farber net>]

Begin forwarded message:

From: "Steven M. Bellovin" <smb () cs columbia edu>
Date: May 22, 2005 10:23:26 PM EDT
To: dave () farber net
Cc: DV Henkel-Wallace <gumby () henkel-wallace org>
Cc: Ip ip <ip () v2 listbox com>
Subject: Re: [IP] more on FCC VoIP 911 order


In message <9D67DA33-6765-4FF5-B269-81FFB982B77F () farber net>, David  
Farber writ
es:

> Consider this implementation: the FCC mandates the following: every
> DHCP client sold must accept a new location identifier.  Every
> commercial VOIP phone or service must get this info and pass it on
> for E911 use.

I believe that this and similar postings are missing the point behind
the FCC's order.  For details, see the May 12 Wall Street Journal; it
summarizes a litany of procedural problems with 911 service from many
VoIP providers.  Here are some quotes:

    Calls from these services sometimes ring at general or
    administrative numbers at emergency-call centers instead
    of connecting directly to 911 operators. In some places,
    those general numbers aren't staffed after normal business
    hours. Even when the calls are answered, the person on the
    other end may not be a trained emergency operator and can't
    see the caller's address automatically.

....

    Vonage says part of the problem with connecting its service to 911
    is that in many areas the regional Bell companies control the
    systems that connect calls to 911 , and the Bells have been
    reluctant to grant Vonage access to the system. For their part,
    the Bells have expressed concerns about keeping the 911  system
    safe from hackers. Some industry observers say the disputes
    largely reflect differences over the terms of connecting.

...

    The letter, from the head of [New York City's] epartment of
    information technology and telecommunications, said Vonage and
    several other Internet-based companies are, without permission,
    sending emergency calls to "a single phone sitting on an
    administrative desk. The only relationship of this phone to the
    city's 911  system is that the desk happens to be located in the
    same building where the city's main 911  call center is also
    located. This phone isn't equipped to serve an emergency response
    or public safety function."

    Vonage spokeswoman Brooke Schultz said the company has asked
    repeatedly for an alternative but got nowhere until recently.

Other complaints are about the web site disclosures and procedures for
dealing with 911 service.

Yes, there are technical issues involving location.  There is indeed
a DCHP option for location information (RFC 3825), and it would probably
be a good idea if cable ISPs were to use it.  But it won't do any good
if the back end systems aren't there, and that will take co-operation
by VoIP providers and conventional 911 operators.


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