| Steve & Susan 2005-05-28, 10:54 pm |
| On Sun, 22 May 2005 10:38:58 -0700, John Nelson
<DieSpammerDie@njabl.org> wrote:
>It is not that simple. Access to the PSAPs is available ONLY via the
>ILEC's. Heretofore, those companies have made it virtually impossible
>for most VOIP providers to gain that access. If the FCC is serious about
>having the VOIP providers deliver E911, they are going to have to ensure
>that the playing field is level.
The 9-1-1 "industry" and the regulatory environment that 9-1-1 exists
in is a nasty business where there are constantly ways of finding
nickles and dimes for business partnerships which are transparent to
PSAPs. It's also hung together like Post-it notes layered on top of
each other. Technology which was put aside in the 70's for telephony
(enhanced MF, like the tones at the end of Pink Floyd's "Young Lust")
is still widely used in 9-1-1. That's layered on top of database
providers, which is layered on top of other database providers, which
is layered on top of... and so on... and so on... . I'd rather see
innovation, but one that moves in an all digital direction which
provides end-to-end digital. ILECs see this as a threat because in a
completely digital environment, they are less necessary (if at all).
In one situation, an ILEC which we retain for selective routing and
database services proposed a tariff for wireless services that would
charge US (the 9-1-1 system... in my case, I operate six primary
PSAPs, one secondary and one disaster recovery) for each wireless
Phase 1 or Phase 2 9-1-1 call we receive. We are not cost-recovered.
We would - hypothetically - have to either fund 9-1-1 from the general
revenue fund, or take the impolitic course of turning off all wireless
access and make 9-1-1 a service provided to taxpayers. Either way, we
lose. The Commission has done NOTHING to aid the several states which
could not develop cost recovery mechanisms, yet the carriers charge a
"Federal Universal Access" fee which, when you pin them down, is
ostensibly for "complying" with 9-1-1 mandates, which in some cases is
not being offered in that area, which some carriers will refuse to
comply with locally until they get their cut from other funding
sources.
Despite these issues, the public sector end of this is constantly
forced to live up to a perceived standard of care that is established
by external factors, such as marketing.
I concur that the playing field has to be narrowed to a common
denominator, however, the FCC is as much a political animal as local
legislatures are. I don't see anything meaningful coming from the
Commission other than another unfunded mandate that is ultimately
passed on to us local 9-1-1 systems.
Steve
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