April 04, 2005

CRTC Rules on 911 Service

Almost a year after its initial ruling, CRTC has spelled out its ruling on offering 911 service to VoIP subscribers. The ruling is bound to be hailed widely, but in my opinion this was a lost opportunity to set an innovative solution that we as an industry should strive to achieve.

CRTC has ruled that those service providers who require their customers to access the service from a fixed location (dubbed “fixed” VoIP service) should offer the same level of 911 service as the incumbent would have offered in that location. To understand the nuance, we have to understand that depending on the location, the incumbents offer either E911 or basic service. If the service provider allows the subscriber to access the service from any place (dubbed “nomadic”), then the service provider is required to offer only basic 911 service. In either case, the service must be operational in 90 days and the subscribers must be notified of the availability and the level of service both in the marketing material, service contract and starter kits. Also, warning stickers must be provided that could be affixed to the telephone sets.

They have also identified a third category of service providers, called “foreign exchange” service providers, who “allow(s) users in one exchange to receive telephone calls dialled as local calls in another exchange that they have selected (e.g. a customer located in Ottawa with a Halifax local telephone number).” The ruling states that these service providers must offer basic 911 service within 90 days. In my opinion, this is an unnecessary classification. Either this foreign exchange service is a primary service or a secondary service. If it is secondary service then for 911 ruling this service is immaterial because this is an incoming call service and 911 is an outgoing call service. If, on the other hand, it is a primary service, then the other two classifications must be used. For example, if I use a Halifax number in Ottawa, but my service provider allows me to access service from a single physical location, then I should get E911 and not basic service.

I feel that most of the VoIP service providers will be able to meet this regulation, because they are already able to support basic 911 service requirement.

This is all well and good, but a bit disappointing in that they should have also set a far reaching objective. I feel thay should have stated that as a goal, the industry should develop a method by which applications can talk to the “physical layer” to get location id that it can use it in its communication to the 911 agency. To take a specific case, the ATA must be able to query the DSL modem and get an ID that it can report it in the session initiation towards the 911 agency. The agency can in turn consult its database to get the physical location, just like it does today in PSTN. Once this is in place, even “nomadic” users can get E911 service. I understand this capability is not available currently; but proddings from agencies like CRTC will help set the direction for the industry.

Posted by aswath at April 4, 2005 06:12 PM
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