FORCE-FEEDING E911

Eventually, as voice-over-IP matures and takes on the stature of a mainstream technology, it should, in the words of Tim Lorello, senior vice president and chief marketing officer for TeleCommunications Systems, be treated like a mainstream technology and do all the things that mainstream technologies do, including E911.

VoIP is far from mainstream today. Despite the upward trend in adoption, the pace is still slow, and the numbers are still relatively small. So it may seem like overkill on the FCC's part to demand compliance to its Report and Order number 05-116 calling for VoIP providers to support E911 services for all customers by Nov. 28.

However, few companies are complaining loudly about that date. They complain about other things, such as a lack of funding, not enough guidance, a weak solution to the nomadic user problem. But the date? They can live with it.

So can their customers and potential customers. In fact, the average consumer with an active interest in VoIP can take or leave E911, according to TeleGeography Research's report, “U.S. VoIP Report 2005.”

The firm surveyed consumers about their interest in adopting VoIP at given price points. After discerning their interest, they asked how interested they still would be, knowing that E911 service would be unreliable. Seventy-eight percent of those who said they were very likely to subscribe to VoIP said they were still likely to subscribe.

“It did have an impact on customer interest in VoIP, but I was surprised how strong the core group's interest still was in VoIP,” said Stephan Beckert, analyst at TeleGeography. “It reduced interest somewhat, but it didn't scare them off.”

Consumers were also asked about reliability issues such as power outages. Those were even less significant than the E911 issue.

“I expected the impact of 911 service to be stronger on consumer demand, but people are aware there is a trade-off and are willing to put up with it for the price,” Beckert said.

He added that given the amount of negative publicity the VoIP E911 issue has received recently, juxtaposed by the phenomenal second-quarter reports on VoIP adoption, it is clear that price is still key.

Those most interested in VoIP, and therefore admittedly less interested in E911, are not the 20-somethings who typically perceive themselves as invincible and not in need of E911. They are the 30- to 50-year-olds who are married, own their own homes and often have families. If anyone besides the elderly should be concerned about E911, it is this group. Yet, they are not, at least as it concerns their VoIP service.

Coincidentally, Beckert saw a correlation between both groups' interest in VoIP and a propensity to go strictly wireless, but that's a statistic for another article.

So if consumers are unconcerned about their VoIP service provider's ability to provide E911, why should the FCC care? Beckert and others point to the obvious: This is still the early-adopter phase.

The push for E911, despite its short-term deadline, is still a long-term strategy. In fact, the case could be made that the FCC action may accelerate rather than forestall the adoption of VoIP by getting some of the E911 issues out of the way for the next wave of adopters who will care about E911.

“The FCC set an aggressive bar to get people out of the [playing] around phase and get them started. They didn't want to create the laissez-faire and prolonged implementation we have seen in wireless,” said Stephen Meer, chief technology officer for Intrado. “There, the world changed so many times over such long intervals that it was like chasing water down a hill.”

Meer said early adopters are willing to deal with more hassle than mainstream subscribers who will have a different set of expectations.

“Part of that will be because there will be very little price difference between the VoIP world and the circuit-switched world by the time the government is finished having its say,” he said.

For the future of mainstream VoIP service, Meer said that the robustness and reliability of E911 will be a huge issue. However, the issues won't necessarily be network issues. And perhaps that's where the downside to rushing VoIP E911 through the system begins to appear. There is more to building a proper solution than throwing some interconnects between the VoIP providers and the public network-based selective routers that point them to the public-safety answering points (PSAPs).

There is nothing in the underlying next-generation infrastructure that has the pedigree of a Class 5 switch, which seldom goes out of service, compared to a router that gets patched and rebooted on a regular basis. “But they're getting better,” Meer said.

Most of what people know about E911, he says, is that someone dials 911 and is routed like any other phone call to a PSAP.

“That's the tip of the iceberg,” Meer said. “There is a substantially larger initiative that deals with provisioning the infrastructure, the interconnections between all participants and managing all the data elements and addresses.”

It's part of Intrado's mission in life to deal with the provisioning problem. Even in today's circuit-switched networks, where there has been plenty of time to get systems and procedures down to a science, Intrado nonetheless employs about 100 people just to deal with the fallout from the provisioning process. So for new service providers, the process could get ugly.

“911 is really about minute details that have to be accurate, timely and scaleable. That's not a view of the world well seen by a lot of folks,” Meer said.

Among those whom Meer doesn't think get it are some of the pure-play IP players and university types that disregard the scalability and reliability requirements for customer bases like those of large telcos.

“There are a lot of folks showing up with greenfield pictures in their heads that, in my opinion, have a reckless disregard for where things are today and what it takes to support a robust service for 280 million people,” Meer said.

Some of those folks also hold the vision of an all-IP emergency network and claim it will flatten out the network and solve some of the interoperability issues. Neither Meer nor others consulted for this article feel that will happen soon.

Introducing IP to the E911 network also worries security-conscious engineers. However, even with the introduction of Internet-based providers on one end of the network, E911 is still a fairly closed system, which provides a good deal of protection from hackers and other ne'er do wells.

Even if and when the PSAPs go to an IP-based architecture, security concerns may not be that great.

“I think there is a misconception around [denial-of-service] attacks and the vulnerability of PSAPs going to an IP architecture. I believe it is way overblown at this point in time,” TCS' Lorello said. “The VoIP service providers are closed environments, and the possibility of getting into that closed network and specifically targeting a PSAP is unlikely.”

Security aside, TCS has seen other issues arise during the implementation of VoIP E911 that cast doubt on its comparative reliability. One issue in particular is the establishment of asymmetrical VoIP calls where the call path is established yet voice only works in one direction. The company has a VoIP verification service, which it uses to test VoIP calls in general and can be used for testing VoIP E911 calls. It has used this tool to gain some visibility into the cause of the problem, which TCS says is an industry issue and may be caused by certain softswitches.

“It can obviously be disconcerting to think a call is working and one of the players can't hear the other,” Lorello said. He added that the problem is not necessarily unique to E911, but E911 happens to bring out that particular flaw. He believes there will be problems going forward in this regard.

While Lorello feels security concerns over the use of IP may be overblown, there are some real quality-of-service (QOS) issues depending on whether service providers use the public Internet or a private data network.

“All players have worked on QOS issues, but there is only so much you can do if you are working on a public infrastructure,” Lorello said.

The upside to that, he added, is the public infrastructure has been so over-engineered that the level of quality won't be that big of an issue right away.

With E911, however — despite the looming QOS problem and the potential for one-way transmission and such maladies — as Intrado's Meer pointed out, the transport network is not an issue that will keep service providers from complying with the FCC mandate.

But logistics might. There are approximately 6000 PSAPs nationwide with which a VoIP provider must establish interconnection. To establish interconnection the two parties must do some testing.

“It was a long, drawn-out process in the wireless industry, and the PSAPs want to work the same way with [VoIP providers] so that will be a time-consuming process,” Lorello said.

TCS has recommended to the FCC that VoIP providers that are ready to test with a PSAP not be shut down or delayed because the PSAP itself isn't ready to test, which was often the case with wireless 911 testing.

And Meer pointed out that not all PSAPs have the capacity to interconnect with the large number of VoIP providers that will be showing up at their doors. Still, the FCC is not cutting providers any slack. Even before getting to the testing stage, the FCC has warned providers that customers' service may shut off if they have not formally responded to notification from their provider about the limitations of their VoIP E911 service.

The notification process has proved to be as challenging as the technical issues. “It's harder to do than meeting the FCC's actual 911 requirements in terms of databases and networking,” said Hank Hultquist, assistant vice president of regulatory policy for SBC.

Why? “Because it's hard to get customers to sign anything,” he said.

Relying on customers to respond to letters from their phone companies in order to prove compliance with an FCC order seems unreasonable, given their history in responding to long-distance and then local competition. So there should be a lesson there for those expecting VoIP customers to self-register their location every time they take their softphone on the road and log on. Yet that is an early-stage requirement for providing location information for nomadic users and probably one of the loosest links in the reliability chain of VoIP E911 service.

So far, the nomadic user does not present a problem for SBC. Its only VoIP customers are business users with fixed location products. Although the FCC has released a notice of proposed rule-making investigating network-based solutions to the nomadic user problem, Hultquist doesn't think that will happen for at least another year.

In the meantime, he has reservations about the accuracy and reliability of the current solution. “Anytime you depend on the customer to do something, there will be times when they don't, so the system won't perform as best designed. There is nothing at this time that can be done about that,” Hultquist said.

Another FCC provision that has some parties concerned about meeting the requirements for E911 is for access to the selective routers that provide connectivity to the PSAPs. VoIP providers see a specific requirement granting them access to the selective router. The incumbent carriers that control the routers say there is no requirement, only an expectation.

“I think the FCC was basing that on their understanding of what was going on in the marketplace, which was people were talking and trying to figure this out. So they didn't see a need for a mandate,” Hultquist said.

He acknowledged there was still some griping going on between VoIP providers and ILECs, but didn't want to judge any particular complaint. He didn't think it applied to SBC.

“I would be surprised if anyone thought we were somehow being a barrier because that would be at odds with the fact that we have been cooperating very well,” Hultquist said.

Vonage Chief Technology Officer Louis Mamakos said the access issue is getting better, thanks in part to the FCC order.

“In a lot of ways, the order has been a great help to us because it legitimizes our access — and the access of the VoIP industry as a whole — to the telephony infrastructure so we can provide 911,” Mamakos said.

Assuming access is in place and connectivity to the PSAPs is in place, Mamakos thinks Vonage will be as compliant as it can get from its end and says his customers are “not too excited” about the prospect of getting shut off if they're not.

“We have a high level of confidence that once we get the address from a customer and know if we can interpret it correctly or not, that we can deliver the call,” Mamakos said. “After all, it's not as if we are using a whole new set of databases; it's just that we're using an interesting new transport technology.”

All this would be great provided the old technology was foolproof, but that isn't necessarily the case, which is why getting VoIP providers up and running by the end of November is not a final solution.

Comparing the public network-based E911 network with the current solution for VoIP, Andy Huckridge, product marketing manager of IP telephony for Spirent Communications, said: “Assuming all the routing issues are worked out — and there are headaches around that — the IP solution can't be any worse than the 911 system we have in place today.”

Huckridge points out that there is not 100% coverage for E911 today and that in many parts of the country, a call will leave the public network and go out on a system that is 20 years old and doesn't even use SS7.

“The [public 911] networks themselves are hit and miss,” Huckridge said.

So far, there are few procedures and solutions in place to test the reliability of E911 service, IP-based or otherwise. “A lot of it is done by hand. That's the actual way E911 is tested today, believe it or not,” Huckridge said.

However, he said Spirent has seen a lot more interest lately in solutions for testing VoIP E911, even though the evidence is circumstantial. Spirent works with PSAP PBX vendors that have started to use its Abacus test product to coalesce the incoming data from the Master Street Address Guide with the computer-aided dispatch system to make sure addresses correspond to the correct phone numbers.

Going forward, it is not clear whether the FCC or state commissions will provide guidance on more involved testing or verifying E911 compliance and performance.

On July 25th, the FCC announced the establishment of a joint federal and state VoIP-enhanced E911 task force. The task force will be staffed by members of both the FCC and state public utility commissions and will enforce the commissions' VoIP E911 rules, including ensuring compliance with the customer notification process as well as sharing best practices.

Members of the task force have yet to be named. Since the recent FCC order is an open item with the commission, it could not provide more details on the agenda and objectives. However, an FCC spokesperson did say that the group would likely focus on both the notification and provisioning issues.

The commission will expect consumers, states and local entities to identify local problems and bring them to the attention of the FCC.

That's two critical pieces of VoIP E911 that are being left partly in the hands of the consumer: self-registration of nomadic users and identifying problems. The solution meets the November deadline; however, in terms of robustness, it is as much in the early-adopter phase as the users who are being mandated to use it.