Re: Vonage Changes 911 to Opt-Out

You are essentially relegating every IP communications device to a 911 caller first and then any other type of communications (and only after the customer jumps through a number of hoops remembering to drop cookie crums so she can find her way back should she need to change something). I agree with you that this solution would probably be a quicker one to implement, but I don't think it would ever be considered satisfactory. Any 911 solution needs to be more transparent to the user than what you describe. Therefore, it probably has to be a technology solution (naturally any technology will be implementing policy!).

Your points about GPS and its relatives are well taken. Sadly, even though I consider your suggested solution inadequate, I have nothing better to suggest at this time ... Frankly I think it's too soon to suggest anything in this field, except that users of VoIP should be

*warned* that their service doesn't include 911. I would hazard the guess that most anyone who at some point in time needs to dial 911 from a VoIP phone, also has a cell available to do that job. Maybe for now we should only mandate that anyone who dials 911 from a VoIP phone should be given an announement to the effect "use your cell phone to make this call!"

Dean

> [[.. munch ..]] >> The "easy" solution is a two-part one. >> Part 1: The VoIP 'head end' tracks the 'most recently used' IP >> address for each customer. _EVERY_TIME_ the customer IP >> address changes, the phone goes *out*of*service* with a >> notice that the customer must update their "calling >> location". >> Possibly with an added hook that if the phone has been 'off >> line' for some non-trivial period, that when it goes back >> 'on line', the customer is queried (in an automated >> fashion) to confirm that they are still at "thus and such >> location"; where "thus and such" is the previously >> specified location for the phone. >> Part 2: The VoIP 'head end' maps the various 'calling locations' to the >> appropriate PSAP, upon need. >> Add an option for the customer to intentionally _not_ specify his >> location, but which also totally disables 911 calling. This protects >> his 'privacy' at the expense of his safety, but it is the customer's >> decision. >> The last part of the puzzle is ensuring that the customer is aware >> that the "location information" provided is used for "emergency calls" >> and that deliberately providing FALSE information can (and probably >> _will_) lead to criminal prosecution if emergency services are >> directed to an incorrect location as a result of said false >> information. There is already existing enforcement mechanism for this >> -- "filing a false police report", etc. > [[.. munch ..]] >> Now, silly as it sounds, something that "works right" 98% of the time, >> but "invisibly" does the _wrong_ thing the other 2% of the time is >> *worse* that something that 'almost never' gets it right. >> An essential element of a 911 'locator' system it that it either gives >> a 'right answer', or it gives *NO* answer. "Wrong answers" are simply >> not acceptable -- wrong answers (a) delay the response to the location >> where it is needed, *and* (b) tie up resources that may be needed to >> respond to a 'real' emergency. >> [TELECOM Digest Editor's Note: Well ... regards your first point, of >> a 'tunnel' to some remote place, do you remember when 'Foreign Exchange >> Service' (or FX) was quite common? > It still exists today. Either as actual hard-wire to the remote CO (with > a *BIG* one-time install charge, plus a moderate monthly) or, more > commonly, > as a 'virtualized' service. >> So, one day in my office, a masked man breaks in, and waving his >> gun around, he announces, "I am going to rob all the cashiers and >> rape all the men". I say, 'oh no you are not!' and rush to my phone >> to call the police. But in my haste I grab up the FX tie-line phone >> and dial '911' -- (or as Bonomi would say, ooops) ... -- and wind >> up lodging my complaint with the politce in Kalamazoo and Timbuck also. > Funny thing about FX lines, the telco _does_ know where the end of > that line is. In your scenario, if you called 911 on that line, while > the call _might_ go to the PSAP for locale where the switch is, the > *location* *information* given to the police would be accurate. > The accurate POTS parallel to the VoIP 'location' problems is the > situation where there the telephone company service terminates at a > PBX, and there are 'extensions' *BEHIND* the PBX to 'remote' > locations. The *telco* _does_not_ _know_ anything about what goes on > behind the PBX, and can only report where =their= service terminates. > Which leads to the telco providing "wrong answers" to the 911 center. > Cell phone systems have the same problem. The point at which a > cell-phone call is connected to the PSTN is _not_ necessarily anywhere > "close" to the tower which is handling the call. AND, that tower may > be in a different 'jurisdiction' than the one where the person > _placing_ the call is. > A review of actual 911 history will show that *both* of the above > scenarios were real problems in the early days of 'enhanced 911'. In > the first case, governmental regulations were issued that require PBX > owners to keep the PSAP 'location database' updated with the > *actual*location* of all extensions that are behind that PBX. > The cell-phone problem was considerably thornier -- and went through a > number of steps: > 1) cell phone links were *blocked* from calling 911 because "wrong data" > was being displayed. > 2) 911 calling was re-enabled when it became possible to return "no > data" for those calls, instead of "wrong data" as to the location. > 3) enhanced technology was mandated/deployed _on_the_cell_ network > (*NOT* a part of the PSTN) that allowed fairly precise _caller_ > location determination 'on the fly'. > 4) Where that technology was deployed, "good" (as in valid/accurate) > 'location' data was then passed to the PSAP, instead of the prior > "no data". > Dealing with VoIP involves much 'harder' problems than either of the > above. To have the phone itself figure out "where it is" it has to > have straight-line inputs from a minimum of two sources that it (a) > knows where are, *and* (b) can take directional bearings on, OR a > minimum of three sources that it can measure signal timing from. AND > it has to be able to reliably derive that information at _any_ > location where the phone might be used. > Using GPS is not a viable option -- 'indoor' reception is too poor. > And the 300 ft accuracy is problematic. That last can be remedied by > using DGPS, but that makes for a more expensive receiver. And doesn't > do anything for the fundamental reception problems. The only solution > for _that_ problem is to replace the transmitters with more powerful > ones. Which is *awfully* expensive. > LORAN-C might be a possibility, it carries indoors fairly well. BUT, > it operates at 100kHz, which requires a non-trivial antenna for decent > reception. *AND* it is only accurate to around 1/4 of a mile. "within > several blocks" is simply not good enough for emergency-service > dispatch. > One is left with the possibility of direction-finding on local > commercial stations. This could possibly be made to work, but > requires access to a fairly massive database of *precise* transmitter > locations. The equipment required to get a precision bearing on a > transmitter isn't cheap, either. (If you're 10 miles from the > transmitter, a _one_degree_ uncertainty in direction makes for +/- > nearly a thousand feet in your location.) > "Technology" is not the solution for this, "Policy" is. The two-part > solution described previously does get the job done. > Administratively, not via technology. All the burden (what burden > there is) is on the VoIP provider and the actual 'owner' of the phone. > And it probably takes 30 days, or _less_, to get it into 'production' > status at any/every major VoIP provider. >> If a _real man_ does not know where his broadband service is out of, >> then he has no business calling the police to start with, does he? PAT] > I stand "corrected". PAT _has_ come up with the ultimate solution. > With his proposed 'local ISP'-based handling of emergency calls, > *NOBODY* but the person who set up the VoIP service -- and knows where > it connects through -- is allowed to use the phone in an emergency. > "So what" if that person is unconscious on the floor from a heart > attack, and the VoIP phone is the only one available, and someone who > _doesn't_know_ that it is an IP phone, or where it connects through, > cannot call for help. > No need to even consider the situation of the person who takes "their" > phone to a friends place, because they may have to make some lengthy > toll calls, and simply _don't_know_ where _that_ broadband service is > out of. After all, that could _never_ happen, could it? > [TELECOM Digest Editor's Note: No, of course it _could_ happen, but > what are the odds? Figure the 'odds' based on these things: the VOIP > phone is on the road somewhere, not in its usual place. The subscriber > has an incident and needs help. Not only does _he_ not know where he > is at (or is not in a position to speak to the police) and the _phone_ > does not know where it is at. There is no landline available, and/or > the person in trouble not only cannot get to the (landline) phone, or > whatever. My personal reaction is _all those factors taken in combin- > ation_ are so negligible as to not matter at all. As soon as any > one of those conditions does not exist, the problem is dealt with. We > do not live in the town of 'Perfect' as the commercial for Walgreens > states. And you know what, Robert? Even if magically, every one of > those rare obstacles were overcome tonight, magically, _YOU_ would > come up with still more obstacles, wouldn't you? And after all, why > not? You swear on a stack of tech reference manuals that _nothing_ can > be done to tame the 'wild west' lifestyle of the internet. I have > never yet seen you ever admit to any possible cure for the nastiness > on the internet. It just has to be the way it is, because Robert has > all the (non) answers. Why shouldn't any problems with E-911 and VOIP > turn out the same way. You don't really want to see any answers to > any of those problems, do you? And rather than do _something_ and > bring some small amount of relief to the vast majority of users, there > will still be some iota-percentage we are unable to help, given our > understandings. So better to do nothing at all, right Robert? I > thought your thinking was absolutely ludicrous where spam/scam/viri > was concerned, but people have seen nothing at all until you explain > the 'hassles' (as you see them) with 911 and VOIP. PAT]
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Dean M.
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