Developing emergency 911 services for wireless callers has been a long, arduous trip -- and just when a glimmer of light appears at the tunnel's end, a promising new technology threatens to take us right back to the beginning.

Many consumers are replacing their traditional residential wireline phone service with VoIP, which allows them to make calls over the Internet. It offers unlimited local and long distance calling for a low price, and gives subscribers mobility -- they can take their home or office number virtually anywhere. Unfortunately VoIP is causing trouble for the new service providers, for public safety answering points (PSAPs) where 911 calls are answered, and for policy-makers in state and federal government.

In mid-May, the FCC ruled that within four months, VoIP providers must give the same emergency 911 capabilities as traditional and wireless service -- this means providing the location and call-back number of people requesting assistance via 911, regardless of the calls' origins.

That's going to be difficult considering the nature of VoIP, which does away with the concept of a "home number."

While the VoIP/911 interface could be a more treacherous ride than the wireless one, recent developments allude to a solution in the works.


All Over Again
The situation, from a 911 perspective, is reminiscent of the migration to wireless phones and the chaos that ensued for PSAPs trying to provide enhanced 911 (E911) services for wireless customers.

To the wireless world, E911 means automatic location information (ALI) and a call-back number for every wireless caller requesting emergency services via 911. The FCC requires that PSAPs be able to locate wireless callers within 50 to 300 meters of their location.

Should the same be required for VoIP phone service?

VoIP can be a boon to businesses because staff members aren't confined to a certain location. "One advantage of VoIP is the mobility of it," said Dan Hawkins, manager of the Public Safety Technology Program for the National Consortium for Justice Information and Statistics (SEARCH). "I can move to a different office, and my extended company may be across town, maybe across the country, and still have the same number and make calls without having to go through all the rigmarole."

If a subscriber moves from California to New York, he or she could retain the California number, including area code, with minimum fuss.

The advantage of mobility, however, could become a liability should the user need emergency services via 911.

When a 911 operator receives a call from a landline, the caller's number and approximate location automatically pop up on the operator's screen, but the system assumes the caller is calling from "home."

When a VoIP subscriber calls 911, if an address appears at all, there is no guarantee the caller is calling from that location.


Pinning the Tail
VoIP providers need only a customer's IP address, not a home address, to provide service. "With the wireless network, there is physical information associated with that handset because it knows what tower it's connected with. That tower has a physical address or place. IP addresses work differently. IP addresses can be assigned anywhere," said Brooke Schulz, a spokeswoman for VoIP provider Vonage.

Until now, VoIP customers wanting 911 services had to register for those services with their VoIP provider by supplying the calling number and a physical address after installation -- that's the only way customers can get 911 services in most areas.

This practice spurred a lawsuit in Texas, filed on behalf of a family who tried to call 911 via a Vonage VoIP hookup. The family received a recording because they hadn't registered their physical address after installation. The suit alleges that Vonage didn't make it clear enough that customers must register to receive 911 services. In a similar scenario, a young girl in Connecticut died after a 911 call was made via VoIP, but again, couldn't reach 911.

Initially Vonage responded to the criticism and the Texas suit by saying it would be irresponsible to automatically include 911 service for an address where the subscriber may not always be.

"We feel if we force them into automatically assigning an address to them, it's actually more harmful because they don't know what they're getting," said Schulz, adding that Vonage has worked diligently to inform its customers that they must activate the service.

Unfortunately many consumers not faced with the immediacy of a possible need to call 911 won't register, said Courtney McCarron, a spokeswoman for the Association of Public-Safety Communications Officials (APCO) International.

"It's kind of like the Surgeon General's warning on a pack of cigarettes; it doesn't hit home until you're dying of cancer."


Automatic 911
Some critics say consumers expect, and should receive, 911 services -- complete with location and call-back number -- without having to register. VoIP providers should work it out technologically and provide the necessary information to the PSAP, just like any other telephone system, McCarron said.

"We think the burden should fall on these new technologies as they come up," McCarron said. "We're all for regulation -- the way it is currently isn't working."

VoIP, just like wireless, is a type of mobile technology, but currently the onus is on the consumer to make sure they have access to 911, she said. "If they don't register, they may not even get basic 911. That's kind of scary."

Further, the nation's 911 systems only understand local phone numbers -- they don't acknowledge numbers from outside area codes, which poses a problem for the VoIP subscriber moving from California to New York and keeping his area code, because the 911 system in New York won't recognize a California area code or phone number.

Some say its time to overhaul the entire 911 system across the country by investing in an infrastructure that replaces the old public switch telephone network. An overhauled system would ideally connect PSAPs to each other and to service providers through IP-based networks that could bypass the legacy environment of wireline circuits and selective routers.

Such a solution is technically possible, but it would require an entirely new architectural approach and infrastructure, according to Kevin Kearns, director of King County, Wash.'s Information and Telecommunications Services Division and chairman of APCO International's VoIP committee.

"So where's the money going to come from for this new utopian vision?"

With wireless, you get a general idea of where the caller is, but that's not the case with VoIP, said Kearns, adding that with wireless, you can't dispatch a fire apparatus or a paramedic to that location and render help to that person. "They still have to be interrogated and give you better information, but at least you have a general idea where the caller was, and through interrogation, you might be able to precisely locate where they are," he said. "With VoIP, who knows? They could be in Shanghai."


Progress?
Some argue that what VoIP providers currently offer is not really a 911 service because the VoIP calls are not sent to dedicated 911 trunks, or routers, but over a regular phone line. The calls are answered by an administrative employee and not a trained 911 call taker.

To avoid competition, phone companies were unwilling, until recently, to sell Vonage access to the equipment necessary to route calls to PSAPs, said Schulz. As of mid-May, however, Vonage entered into an agreement with Verizon that will route calls to 911 operators instead of an administrative phone line.

As part of the agreement, Vonage will be able to purchase access to a pseudo-automatic number identification (pANI) information database and the selective routers that direct the calls into the 911 system and to the local PSAP.

The pANI database, which consists of local numbers assigned as substitutes to VoIP subscribers with nonlocal numbers, will allow nonlocal numbers to be recognized by and properly routed through the 911 system.

"So basically, this takes out the regular number and puts this pANI number in one of the fields that assigns it to a trunk group, like an actual physical wire that goes into the selective router," Schulz said. That process would direct the call to the PSAP nearest the caller.

That process too has its limitations. While it resolves the outside number problem, there is still no way to track the device if, for example, the caller is on the road with a mobile device, such as a laptop.

The setup, according to Vonage, is expected to be similar to an implementation in Rhode Island. Beginning in October 2004, VoIP subscribers in Rhode Island could request 911 services, and the 911 system uses pANI information and selective routers to recognize the VoIP call request and locate the physical address provided by the subscriber at the time of purchase.

But if the VoIP user is not at the physical address on file, the caller would still have to tell 911 where to go, said Raymond LaBelle, executive director of the Rhode Island E-911 Uniform Emergency Telephone System. "If someone cannot communicate, it would be like in the old days and we wouldn't be able to find them," he said. "We don't get location information or even a call-back number."

SEARCH's Hawkins said he still wonders how Vonage is going to provide the location of those callers. "There is a less-than-educated opinion that there could be some GPS coordinates," he said. "Well, GPS doesn't work well inside of buildings, and the larger the building, typically the less well it works."

Schulz said absent that kind of technology, it's up to callers to provide location information should they become mobile. This is how it works in Rhode Island, where Vonage has taken advantage of access to pANI information and selective routers to provide basic 911 capabilities to consumers.


Wheeling and Dealing
PSAPs pay phone companies to operate 911 systems, and phone companies own the pANI information and selective routers in every state, except Rhode Island. In Rhode Island, the state's E-911 Uniform Emergency Telephone System owns the 911 system -- including the pANI data and selective routers -- and operates it as a service to the state.

Vonage and Rhode Island have cooperated to enhance the 911 capabilities for VoIP customers living in the state.

The Rhode Island/Vonage 911 partnership and the Vonage/Verizon project, while not long-term solutions, signal that the VoIP/911 interface won't endure the lingering hardships that establishing E911 for cell phones did, according to APCO's McCarron.

Making the selective routers available is a big hurdle and a sign of progress, according to Steve Seitz, director of Government Affairs for the National Emergency Number Association (NENA). "If you would have asked the wireless community if they would have liked to have had selective router accessibility 10 years ago, they would have loved to have had it," he said, adding that NENA has refrained from adopting a "provide-911-service-or-else" attitude with the VoIP community. It instead provides guidelines through NENA's Web site.

"We're trying to give them a pathway to do it efficiently, and to do it in a context and a framework," Seitz said. "If you just say, 'Connect any old way,' then I guess we're going to run into 10 years of problems of, 'Oh, we didn't mean this. You should have done it this way."'

Another hurdle is that the money and scalability issues could make it tough on some VoIP providers to comply with any regulations that might require them to develop capability for 911 emergency services.

"With VoIP, you have a bunch of small players coming to the market," Seitz said. "If you have a server and a customer base, you essentially could be a VoIP provider. The provider in the basement may not necessarily be able to provide the same suite of services one of the bigger players could."

It's an issue that's going to take some clear deliberation to avoid the wireless route, he said, and NENA is trying to say that everybody should have access to 911 services. "Let's say that's the initial goal. But along the way, you're going to have to have some serious discussions on what that means."

Jim McKay, Justice and Public Safety Editor  |  Justice and Public Safety Editor