May 24, 2005

Duck Test is Not Reliable

In response to my previous post on FCC ruling on E911 service, Frank Muto suggested that use of ATA and standard phone could be the deciding factor in determining whether a service is interconnected or not. Martin Geddes also suggests that for consumers this is a simple test. A little analysis will suggest that this classification scheme doesnít resolve the issue.

I am of the understanding that players like Free World Dialup are exempt from this ruling because they do not offer interconnection to PSTN. But they do allow the use of ATAs. So FWD needs to offer E911 service? That will be interesting, especially given the fact that they have been previously granted exemption from regulation.

Use of PC can not be a guide as well, because then we have to define PC.I suppose a fair definition could be PC is something that has a processor, OS, input and output devices. Doesnít ATA+2500 set a PC then? After all it also has a processor and an OS; the mike and keypad are the input devices and the speaker is the output device. There are reports that Skype will embed their software in home routers, thereby making the router to be an ATA. At that time, does Skype have to offer E911 service?

Presence of RJ-45 (or is it RJ-11?, asks DG Lewis; it doesnít matter) is not that reliable a measure either. There are some devices that have integrated the ATA functions and a cordless phone. They do not have a RJ-11 jack and have only a RJ-45 jack. Does that mean an integrated device exempt from this ruling?

I donít think using the form factor of the user device gives us a good solution.

Added: After posting this entry, I noticed that Om also feels Duck test is appropriate.

Posted by aswath at May 24, 2005 04:34 PM
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Aswath, I fully agree with you. The plugtest is not reliable. But what is also not reliable is the requirement from the FCC that VoIP providers not connected to the PSTN need not to provide access to emergency services. Finally any device connected to the Internet must provide access to emergency services, because otherwise there would be no emergency services if the PSTN runs out. But this cannot be solved within some month. See also my comment to Martin.

Posted by: Richard Stastny at May 24, 2005 08:35 PM

Even though the recent ruling is billed as a requirement on VoIP service providers, this will turn out to be solely a requirement on the incumbents that IF a VoIP service provider requests access to E911 network, then such a request must be granted.

For more reason than this, I hope that PSTN will not run out.

Posted by: Aswath at May 25, 2005 12:18 AM

It has to, because in some years nobody can afford to run it, for less and less subscribers. Also the incumbent manufacturers will not ba able to support it any longer. There is also no experts left, not with Telcos and not with manufacturers. They either left the company to do something more interesting (guess what) or are retired. Do a head count in any telco on SS7 specialists. If you need two hands it is a very large telco.

Both ETSI TISPAN and ATIS are currently spezifying the NGN subsystems PSTN emulation and PSTN simulation. This sounds very much like PSTN replacement.

Posted by: Richard Stastny at May 25, 2005 02:13 AM

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