Voice Over Internet Protocol (VoIP) & 911

In early 2004 several companies began marketing local and long-distance VoIP telephone service to residential consumers, raising several E911 issues. The servicer had long been offered to business customers, but generally for call center, long-distance or international situations that didn't require E911 service.

The service uses an Internet data connection to connect a standard telephone device to another similar device, or to the public switched telephone system, in order to connect to any telephone in the world. The technology has been used for several years by business customers, primarily to reduce the cost of international and long-distance calls.

While providing some important cost-savings to consumers, current VoIP technology does not provide for the transmission of the caller's physical location along with the voice call. If the caller dials 911, there is no inherent protocol within the VoIP technology for routing the call to the nearest PSAP, or to display the caller's location, telephone number or other information.

The FCC has a Web page devoted to the regulatory issues of 911

Another issue involves E911 funding-- VoIP users can arrange for E911 service with their Internet provider, and yet not pay any applicable 911 surcharges for the service. There is anxiety among public safety agencies, county and state-level 911 agencies that E911 system funding could be reduced as more persons convert to VoIP telephone service, and drop their wired telephone service.

Several Internet groups (including the Internet Engineering Task Force) are working on enhancements to the underlying Internet protocols to allow additional data to be transmitted, including data related to voice calls, and specifically 911 calls. However, until the protocols are formally developed and approved, and the Internet enhancements implemented, persons dialing 911 from a VoIP-enabled telephone may not reach the appropriate PSAP, and may not have their location or call-back number display for the calltaker.

The Internet groups and other stakeholders have identified three phases for the transition to a fully-E911 capable system:

  • I1 - now, routing to 10-digit administrative number allowed, stationary (fixed) service only, no caller location transmitted, but no modifications required by PSAPs to handle incoming calls
  • I2 - deployed by late 2004, no routing to 10-digit numbers, stationary and nomadic service, caller location transmitted, ALI database modification required, no modification required by PSAPs
  • I3 - unknown deployment, no routing to 10-digit numbers, stationary, nomadic and mobile service, caller location transmitted, PSAP modifications required, ALI database replaced by domain name server

Read a description (pdf) of the phases Prof. Henning Schulzrinne of Columbia University.

Several companies are already marketing consumer-level service, including Vonage Inc. and Packet8 Inc. Both have optional E911 dialing programs, which allow the customer to subscribe for a monthly fee, to submit the physical location of the VoIP device, and then to have any future 911 calls routed to the appropriate PSAP. Both of these companies have Web sites that are quite explicit that E911 service is not included in the basic package, the limitations on dialing 911, and that their VoIP devices operate on AC power, making the phone unusable during a power outage.

However, even with a registered VoIP telephone, there are hazards. If the subscriber takes the device on the road to allow long-distance or international calling, any 911 call from the device would be routed to the registered PSAP, back in the home region of the subscriber.

Right now, several companies are attempting to get a jump on the promising consumer VoIP market, including telecom giant AT&T. They, in turn, are hiring companies to provide the switching gear and call routing services for E911. The very early VoIP providers seem to be concerned about the E911 issues, and are attempting to be up-front about the service with consumers, and to provide the service without any legal requirement.

However, the FCC opened a formal study of VoIP in June 2004, and held the first in a series of forums on the technology--understandably, the first session focused on E911. The FCC will eventually approve some degree of regulation for the growing VoIP industry, no doubt including mandatory E911 service. In May 2005 in-coming FCC Chair Kevin Martin said he was close to proposing VoIP/E911 rules and, not surprisingly, within days both Verizon and Bell South agreed to allow VoIP providers access to their E911 switches. The service would be limited by geography at first, but eventually spread to all of the companies' service territory. It would allow VoIP providers to route calls to the local E911 tandem, and have the calls routed to the appropriate PSAP. This change would not change the thorny technical issue of how VoIP callers should register their location so that a correct ANI/ALI is transmitted to the PSAP.

On May 19, 2005 the FCC issued a proposed Order that would require VoIP providers to offer E911 service within 120 days of the Order's formal passage. That action has kicked off all sorts of debate over whether it can technically be done within that period, how it will affect VoIP development in general, and a whole raft of issues at the PSAP end.

Interestingly, the push for VoIP service has also raised a positive issue for public safety comm centers--the possibility of upgrading local and regional E911 systems to use the VoIP technology, and to then use VoIP to create a national E911 system. Such a system could allow quicker call routing, easier network management (re-routing 911 calls during outages, etc.), and the possibility of routing 911 calls to and from any PSAP in the country.

On March 30, 2006 VoIP provider Vonage said that 1 million of its subscribers had been linked to E911 directly, and that it took the company just 9 months to make the connections.

In late March 2006 Rep. Joe Barton (R-Tex.) has floated new legislation titled the "Communications, Promotion, and Enhancement Act of 2006" that is aimed at the TV industry, but which also contains a provision that would require VoIP providers to offer full E911 service to their customers. Up to now VoIP providers have been mandated by the FCC under regulations that were less specific. Besides the E911 mandate, the bill says that VoIP providers "have the same rights, duties and obligations as a requesting telecommunications carriers" under the Communications Act of 1934, which provides the company's with certain liability exemptions. That, in turn, should allow them to provide E911 service sooner. Download (pdf) the proposed bill.

Read this "PC World" magazine article for a decent explanation of the current VoIP/E911 situation as of early June, 2005.

Resources

  • FCC Web page on VoIP, with links, description of VoIP and other information
  • The Internet Engineering Task Force is working on the VoIP/E911 issue through a working group (ECRIT)
  • Joint FCC/NARUC Task Force on VoIP 911 Enforcement information Web site
  • FCC consumer fact sheet on how VoIP works [pdf]
  • NENA's VoIP/E911 information Web page / article collection
  • VoIP/911 site operated by Greater Harris County 9-1-1 Emergency Network
  • VoIP/E911 information from Packet8's Web site
  • VoIP/E911 information from Vonage Web site
  • Warning flyer issued by Weston (Fla.) on the limitations of Vonage VoIP 911 service [pdf]
  • Presentation by TeleCommunications Systems on VoIP issues and possible solutions [pdf]
  • Intrado VoIP 911 services (pdf)
  • "VoIP News" Web site - industry news and information
  • Presentation by Prof. Henning Schulzrinne, Columbia University, general VoIP/E911 issues (pdf)
  • Presentation by Prof. Schulzrinne (pdf)
  • Presentation by Prof. Schulzrinne in 2003 on general VoIP/911 issues (pdf)
  • Presentations during 2004 NENA conference [#1] [#2] [ppt]
  • Commercial courses on VoIP and 911 issues
  • VoIP and 9-1-1: What You Need to Know About Online Emergency Service - Oregon info [pdf]
  • VoIP coverage on the CyberTelecom Web site
  • King County (Wash.) Web page warning on VoIP/911 limitations

    Actions

  • Texas Attorney General files lawsuit against Vonage Holdings over E911 service 3-23-2005
  • FCC sets rules for VoIP/E911 providers to notify all customers of limitations of 911 service and to receive 100% acknowledgements from them. [pdf]. 6-25-2005
  • Petitions for reconsideration filed by CompTel, T-Mobile, NENA. 7-29-2005
  • Prof. Henning Schulzrinne, Chair of the Columbia University Department of Computer Science, comments to the FCC on challenges and opportunities of the 911 system. [pdf] 8-17-2005
  • NENA asks FCC to create a "a permanent, national administration" function for E9-1-1 routing control codes for VoIP E9-1-1. 8-22-2005
  • NENA publishes "Interim VoIP Architecture for E911 Systems" standard. [pdf] 2005
  • VON Coalition asks FCC for relief from August 29th deadline on VoIP/E911 notification rules. 8-26-2005
  • FCC says it won't enforce VoIP/E911 acknowledgement deadline until Sept. 28th (was Aug. 29th), but only under certain conditions. [pdf] 8-26-2005
  • FCC names members of joint federal/state panel for VoIP/E911 enforcement. [pdf] 9-1-2005
  • FCC says it won't enforce VoIP/E911 rule, since most providers received over 90% acknowledgements from customers. [pdf] 9-27-2005
  • Provider Nuvio petitions for stay of Nov. 28th deadline. [Part #1 / #2] 10-24-2005
    The Issues Now
    • educate VoIP customers on limitations of E911 service
    • link all VoIP providers to E911 switches so calls are routed directly to appropriate PSAP
    • long-term solution to ALI/location issue
  • FCC says VoIP carriers don't have to terminate customers who didn't return notification letters. [pdf] 11-8-2005
  • U.S. Senate subcommittee approves S. 1063 that would regulate VoIP/E911 [pdf] 11-9-2003
  • Vonage requests FCC waiver of deadline on E911. [pdf] 11-28-2005
  • APCO issues position statement on Congressional VoIP legislation. [pdf] [Exhibit #1 #2 #3 #4 #5 #6 #7]12-1-2005
  • APCO creates Project 41 to study VoIP/E911 matters.