[VOIPSEC] VOIP for free??
BWilliam at wutc.wa.gov
Thu Apr 14 00:27:06 BST 2005
I am aware that a NENA standard is due out soon but have not seen the
draft. I am also aware that the IETF ECRIT group (transport) is working on
emergency services but have not checked to see if the April 5 RFC actually
came out on that date. Yes those are some of the "real" standards that must
be completed before "real"solutions can be completed. The new standards
must take into account the existing 911 protocol and interconnection
standards. Sadly many of those new standards could already have been
resolved in the early days when many in the IP community hid their heads in
the sand under the pretext that the Internet would never have to deal with
I use Skype often (England, Whales, Afghanistan, and even D.C., the best
codecs around with incredible clarity except to Afghanistan) computer to
computer as well as Skype out, and I have never expected the ability to
reach 911. The danger, as I'm sure you are aware, is that whatever device
you use for telephony will be used by your baby sitter who may not be aware
that it isn't 911 capable. I doubt a baby sitter will logon to a computer
to dial 911. Just as in the case of Vonage vs Texas it will be the courts
not the sanity of standards groups who may drive the direction of IP
telephony. Very sad it didn't need to be that way.
The PSAPs are badly in need of a complete redesign around IP. The cost as
usual is the rub. Changes, redesigns, standards will only be only applied
if there is money to accomplish them.
I tire of hearing some IP providers say that they pay for 911. I can verify
that some do (CLEC IP providers like AT&T, MCI, Level3 and others) and many
don't (Vonage, 8X8, and others). In most states (including mine Washington)
it is difficult to remit 911 fees because a provider must deal with each
county as well as the state. We have offered to help negotiate with our
state office and those providers to, even if temporarily, soften that
stance and receive funds at the state level that would then be given to the
correct county. So far we have had no takers.
Yes there is good evidence for applying charges to access. That is one of
many theories being discussed. Whatever is decided, regulation by
technology will always be a loser. Legislating for IP may not allow for the
next better nascent technology to bloom. An even, light regulatory touch
for all (wireline, wireless, IP, etc) seems to be the most fare. Just some
light protection from monopoly behavior no matter what the flavor.
Federal pre-emption may not be the boon that many hope for. It was Jeff
Pulver who recently stated that state agencies may be you next best friend
since they have always been the protector of competitive local access. Even
though the FCC stopped Vonage from being port blocked they may not in the
future depending on the court decision in the Brand X case. Access may be
the next pinch point, telephone companies must provide common carriage and
equal access, cable companies don't. Because of changes by the FCC, access
at reasonable prices may be an issue too.
The technical issues are much more fun and more readily attainable! Solve
the technical piece and the regulatory piece will follow. Keep up the good
dialogue! Notice I didn't mention inter-carrer compensation, the universal
service fund, etc. Even I have a threshold of pain.
<br at brianrosen.ne
04/13/2005 01:09 <BWilliam at wutc.wa.gov>
<aldem-voipsec at aldem.net>,
<voipsec at voipsa.org>,
<Voipsec-bounces at voipsa.org>
RE: [VOIPSEC] VOIP for free??
There is a standard for how to do this, just about ready for publication
from NENA. It's an interim (migration) standard that doesn't require
changes at the PSAP, but costs the VoIP carriers what I expect will be an
We're working on the "real" standards at the IETF and NENA. That will, I
hope, meet the parameters we are discussing.
We are discussing the funding issue. It's complex, and this is not the
right venue, but...
9-1-1 funding is a combination of general revenue from local jurisdictions,
various fees on service providers, and surcharges on phone bills.
The latter 2 will probably fade away. The non-local characteristic of the
service providers means you can't effectively get them to handle a
surcharge. Folks like Skype don't even bill.
So, I have proposed that we shift the fees and surcharges on communications
service providers to a surcharge on access. It's applied uniformly to ALL
access providers. We use some really simplistic metric like bandwidth or
percentage of bill to apply some level of fairness. It applies to ALL
access networks which includes broadband, wireline, and wireless, and all
flavors of each (so including cable, DSL, WiMax, ...)
You will note that these are exactly the same folks who have to supply
There is precedent to allow carriers who are given some kind of obligation
like location determination to offset a portion of their costs against the
surcharge. We do that; we impose an obligation to provide location, and we
defray some part of the cost out of the surcharge.
Access providers are always there, and always local (and thus always
to local regulation). In this case, I expect we will actually get federal
regulation that preempts state and local regulation, but we'll see.
From: Bob Williamson [mailto:BWilliam at wutc.wa.gov]
Sent: Wednesday, April 13, 2005 2:51 PM
To: Brian Rosen
Cc: 'Alexander'; voipsec at voipsa.org; Voipsec-bounces at voipsa.org
Subject: RE: [VOIPSEC] VOIP for free??
Interesting string dealing with difficult issues. I for one, after watching
the market place in the last few years (WorldCom, Qwest, etc), am concerned
that business will always be for making money not taking care of societal
needs. Some form of light touch, but effective, regulation may be the best
way to control that drive for profit at all cost. Maybe I just getting a
bit older and a bit jaded. If it is still a social imperative to make sure
that all American's have access to reasonably priced voice communications,
which includes access to emergency services, then it must be paid for by
subsidies, no ones favorite subject.
VoIP, location, and 911 is a mix of cost, tax, and technical issues. IP
addresses don't provide location particularly if the IP device is behind a
NAT and firewall. Smart LAN jacks for business have been discussed but not
finalized. Triangulation hasn't worked with WIFI/WIMAX (unlike cellular)
and may never be possible. GPS is not always accurate within buildings. I
am confident however that the technical issues can be resolved and are
actually now getting the attention they disserve. Accurate location isn't
just important for 911 but also provides good business opportunities so it
will be solved. A technical VoIP trial was just successfully completed in
King County (greater Seattle area) in cooperation with the local 911 PSAP,
a number of companies (VoIP provider, RBOC, 911 database providers, etc.),
and a little help from the state utilities commission. It was successful by
providing accurate call back information and address to the correct 911
operator (just deciding which 911 operator location requires major data
base work). The method was not standard and has been forwarded to the
appropriate standards organizations for their approval. The test required
the consumer to update their address information on the company website any
time they moved. The address information was updated in the appropriate
data bases within 15 minutes (instead of the week it takes now). If nothing
else making the consumer update address info. every time they unplug and
replug their IP device would be a temporary simple solution (of course the
consumer could spoof the system by inputting any location).
No matter how you feel about it the solution and/or regulation continued
open dialog is the best path to resolution. Keep it up!
Security is of course a bigger problem.
Senior Member Technical Staff
Washington Utilities and Transportation Commission
<br at brianrosen.ne
Sent by: "'Alexander'"
Voipsec-bounces at v <aldem-voipsec at aldem.net>,
oipsa.org <voipsec at voipsa.org>
04/13/2005 05:17 Subject
AM RE: [VOIPSEC] VOIP for free??
While I expect that we will see some very "light touch" regulations on U.S.
VoIP service providers, I don't think that we can count on that to get the
kind of service we want. We have to make it so easy and inexpensive to
handle an emergency call that they all do it because they have a very small
liability if they don't, but the cost of complying is smaller than the "net
present value" of the liability. If it takes a couple hundred lines of
code, and nothing else but an Internet connection, I think that would do
The fundamental problem with regulation is that you can't regulate non-U.S.
suppliers, and yet they can offer the same services to U.S. customers.
I have reason to believe if we do make it that easy and that inexpensive,
then systems like Skype (your example) would implement what is necessary.
That's the plan. Of course, Skype has PSTN connections now.
You are very wrong about devices that look like a phone and don't offer
emergency call services. There are very few such devices except VoIP
devices that look like phones and don't work for emergency calls today.
Many, many people care, especially the authorities. Sometimes the
authorities are misled by incorrect assumptions made by service providers
their costs of complying, or by vested interests whose business is better
served by high costs and low compliance rates.
Let me ask it to you this way:
If it costs a service provider an average of $.0001 per month per
to support emergency call services, and one person per year per service
provider loses their life because they couldn't get help from the service,
is that a good tradeoff?
Suppose it was $.001 per sub per month? $.01? $.1?
Suppose one person sues the service provider because they didn't provide
service? Would that be a good tradeoff?
Now, if it costs $1 a month a subscriber to provide the service, and you
have 10M subscribers, then you can decide if its worth it. Maybe it would
be to you. Probably not to me, but at least we're in a range where you can
make the argument with a straight face.
I'd like the cost of compliance to be a couple hundred lines of open source
code, and access to a public routing database.
Now, this does NOT include the issue of location determination, which is a
more substantial cost, born by the Access Infrastructure Provider. That's
bigger deal, and more difficult, and probably subject to more regulation,
and a more level playing field for the regulation (the AIP is always
From: Voipsec-bounces at voipsa.org [mailto:Voipsec-bounces at voipsa.org] On
Behalf Of Alexander
Sent: Monday, April 11, 2005 7:24 PM
To: voipsec at voipsa.org
Subject: Re: [VOIPSEC] VOIP for free??
On Mon, Apr 11, 2005 at 09:14:50AM -0400, stuart jacobs wrote:
> Unfortunately, in the USA, the Federal Communications Commission (FCC)
> does care about 911 and mandates support by any supplier of
> telecommunications services currently over the PSTN but will eventually
> apply to non-PSTN Local communications system as well.
What about closed services like Skype? There might be community with
computer-only network (i.e. no access to/from PSTN at all) - will this
be considered as "telecommunication services"? If yes, what about 911
routing, if there are (say) no phone numbers involved?
To be honest, I don't really understand why anyone who is offering voice
services (whatever it is - VoIP, Skype or like) must provide 911
routing... No, "looks like phone" is not an argument here - there are
many devices which looks like phone and are not capable to provide 911
or equivalent service, and nobody (including authorities) cares.
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