Counter-Point: FCC Order on 911 Necessary for Companies to Fulfill Their Obligation to Public Safety

The following is a letter from APCO International President Gregory S. Ballentine in response to an editorial on Government Technology's Web site by Jeff Pulver, president and CEO of the voice over IP (VoIP) provider Pulver.com. In his editorial, Pulver deplores the FCC's recent order requiring small independent VoIP service providers to give their customers access to enhanced 9-1-1 services without at the same time requiring that established telephone companies share access to the capabilities of their existing networks that would make providing local E9-1-1 services feasible.

Gregory Ballentine
The Association of Public-Safety Communications Officials (APCO) International is the world's oldest and largest professional organization dedicated to the enhancement of public safety communications. APCO International serves the professional needs of its 16,000 members worldwide by creating a platform for setting professional standards, addressing professional issues and providing education, products and services for people who manage, operate, maintain and supply the communications systems used by police, fire and emergency medical dispatch agencies throughout the world.

On behalf of APCO International, I must express my concerns regarding comments made by Jeff Pulver in the May 27 Government Technology Executive News editorial "FCC E911 Order Discourages Innovation and Hampers Long-Term Emergency Response Capabilities." APCO International is deeply concerned that the rapid deployment of Voice over Internet Protocol (VoIP) service will have a serious, negative impact on the provision of 9-1-1 emergency communications across the nation. Therefore, APCO International supports the Federal Communications Commission's (FCC) actions to ensure that all interconnected VoIP calls provide full enhanced 9-1-1 (E9-1-1) capability.

I must admit that I take exception to Mr. Pulver's comment suggesting that "no one" is more concerned about ensuring emergency response for our citizens. If this is so, I would assume that the VoIP industry would have ensured that their services met current 9-1-1 requirements before subscribing millions of consumers and, if that were the case, the 120 day requirement would not be an issue. Simply stated, lives are put at risk when access to emergency services is an afterthought to new communications technologies.

The public has an expectation that telephone services will provide 9-1-1 and E9-1-1 capability, regardless of whether the telephone operates on the public switched telephone network (PSTN), wireless networks, or the Internet. Yet, at present, there is a very real likelihood that a 9-1-1 call from a VoIP telephone will be lost, delayed, or misrouted. In addition, VoIP services are currently being sold to the public without disclosure of its shortcomings with regards to 9-1-1. As long as VoIP providers continue to sell services without meeting current E9-1-1 requirements the public will remain in harm's way. Anyone present at the Open Commission Meeting on May 19 to hear about the very real consequences of the current state of VoIP services would agree that FCC regulation is not the problem, but the solution.

Taking shortcuts to avoid social obligations, such as E9-1-1, puts the consumer at risk. It is true that E9-1-1 should never be used as tool to bring down an emerging industry, but its positive impact on emergency response should not be taken lightly. Any delay in providing E9-1-1 will inevitably result in the loss of lives. Unfortunately, the Waller family in Volusia County, Fla., has already experienced the negative impact of the less-than-acceptable emergency services currently provided by VoIP systems. The long-term promises of VoIP should never be allowed to put the lives of consumers in harm's way.

Thank you for your time and for allowing me to express APCO International's concerns.

Sincerely,

Gregory S. Ballentine
President
APCO International