Does Your VoIP Carrier Meet the FCC's E911 Requirements?

Carl Weinschenk

Carl Weinschenk spoke with Pat Halley, Government Affairs Director for the National Emergency Number Association.


Weinschenk: How do the E911 and traditional 911 landscapes differ?
Halley: In the past, there were only a handful of major local exchange carriers. They were known quantities. When wireless came in, there were only five major wireless carriers and several tier 2 and 3 players. For the most part, the majority of America uses wireless from a known quantity. With VoIP, it's so much easier to get into the market, almost anyone can develop VoIP if you have some technical ability. That [makes 911] a challenge for smaller and newer companies, some with only two, three, four or five employees to understand and comply with the e911 system. You have companies like Vonage and in the same space companies that I've never even heard of. It's really difficult, I think foolish, to expect a small mom and pop IP service provider to have the same capabilities.


Weinschenk: The rules went into effect late last year. There are VoIP companies not offering E911 at all and some not offering it across their entire footprint. This appears to not comply with the rules. Are these companies breaking the law?
Halley: They are in violation of FCC regulations. It's unclear what the FCC intends to do about that at this point. But, yes, they are in violation of the law. The FCC said their regulations have to be met. There are certain exceptions. There are lots of nuances. If we are talking about residential consumers or multi-line telephone service, there's debate about whether all of the FCC rules equally apply to multi-line telephone service. There is still confusion how they apply to MLTS. But the FCC said the rules must be met by November 28, 2005, and if you can't meet those rules, they expect providers to stop marketing and offering new service in any areas where they can't meet the order. I'm aware of one company in West Virginia that has gone out of business because they couldn't meet the rules. The FCC eventually will enforce the rules and enforce penalties or in a given circumstance may see that the company is making a good faith effort and may grant an extension to meet the rules. At this point, it's unclear what they are going to do. Over 200 compliance letters were filed last year, and 35 to 40 requests for waivers.


Weinschenk: Most companies don't rely on E911 themselves. It's more of a consumer issue. But if these companies get in trouble and go out of business, that would affect their corporate clientele. What should a business look for when interviewing potential vendors?
Halley: If the company seems confused about why it needs to do e911, I would walk away. I would look at what they are publicizing as far as e911 capabilities. Look at what kind of provider they are. Are they a fly-by-night? If they are, they likely have less experience to implement an e911 solution. I will tell you Congress is very much interested in this debate. If they believe the FCC rules are too stringent and are preventing competition or putting phone companies out of business, they may be even more active than they already are. The administration is very supportive of FCC e911 rules.

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