Jeff Pulver responds to FCC Chairman Martin's comments on VoIP

Commentary from The Jeff Pulver Blog: April 27, 2005

'Help! I Need Somebody!'... But do we really need Somebody to Micromanage Emergency Response Solutions for IP-Based Communications?

Last night I read with some concern several news accounts of a comment FCC Chairman Martin made yesterday regarding application of emergency response obligations on VoIP service providers.

Now, to be clear, I have no problem with the adoption of appropriately-tailored rules establishing guidelines for implementation of an emergency response system for IP-based communications providers. Who could argue with the promotion of such a public good? As I've said repeatedly, IP technology will allow for the establishment of next-generation emergency response capabilities that will dwarf anything we currently see on traditional telecom networks.

In fact, the Global IP Alliance, which I helped to found, is now taking the lead to develop a global IP-based Emergency Response System. It is my hope that this global effort will allow users to hit a single button and immediately activate appropriate language translations, notify appropriate points of contact and emergency responders, transmit individualized medical histories and special circumstances, etc.

New rules designed in such a way so as not to disrupt new technology and services but ensure the public good should be acceptable to both industry and government. Cookie-cutter application of old rules to IP-based communications, however, could tend to stifle new technology and innovation and interfere with the ability of IP-based communications providers to develop superior emergency response systems.

My preference of course is that industry take the lead to develop non-proprietary emergency response systems that are most suitable to promotion of IP technology while promoting the broadest public good. Short of that, I would hope that regulators, as they inject their authority over IP-based communications, look at IP technology with a fresh eye and an understanding of the differences between IP-based communications and traditional telecom networks.

One area where I think it is appropriate for government intervention would be to ensure that unaffiliated IP-based communications providers have access to the "selective routers" and other infrastructure currently controlled largely by incumbent carriers. I would hate to think that those that control necessary infrastructure could stand in the way of establishment of a workable emergency response capability by IP-based communications providers. Certainly, lives should not be lost so that certain providers might be able to maintain a competitive advantage or point to the inadequate capabilities of unaffiliated IP-based communications providers.

Another area for government oversight would be to ensure that PSAPs do not block the use of administrative access lines for nomadic emergency response services. These administrative access lines provide a critical interim solution while the IP-based communications industry moves forward rapidly to develop the technological means for the provision of emergency services to nomadic end users.

I'm curious to see the fruits of Chairman Martin's statement and I trust that he will not simply "react" to current fears as he and his colleagues weigh in on emergency response solutions that might implicate IP-based communications. Any regulator involvement must continue to promote innovation and advance the promise of IP-based communications while simultaneously promoting the public good and allowing IP technology to improve emergency response solutions.

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Jack Decker
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