WASHINGTON-The National Emergency Number Association asked the Federal Communications Commission to establish an interim, then permanent, Routing Number Administrator, a move that would benefit Voice over Internet Protocol providers facing difficulties routing enhanced 911 calls as they race to deploy E-911 service.
“Both for current VoIP needs, and as an improvement for the wireless arena, NENA believes that a national RNA is critical. The instant need is obviously for VoIP E-911 applications in order to support and move forward in accomplishing the commission’s VoIP E-911 objectives. A single point, with neutrality characteristics and experienced in numbering data management, is desirable in order to minimize startup time and bring effectiveness to this national function in support of E-911 service needs,” Roger Hixson, NENA technical issues director, told the FCC’s Wireline Competition Bureau.
In the wireless context, calls are assigned with a pseudo automatic number identification based on location so the call can be directed to the correct public-safety answering point.
Fake numbers are unnecessary in the wireline context because the location of the 911 caller is fixed at the location assigned to the telephone number. While most VoIP users also are fixed, they often choose a nongeographic area code so callers in another part of the country can call them locally. This makes the numbers no longer tied to the nearest PSAP.
NENA told the FCC that after an attempt to create an RNA for wireless was unsuccessful, incumbent local exchange carriers took control of the distribution of p-ANIs.
“VoIP service providers have neither direct number assigning authorization nor the ability to readily acquire numbers for 911 call routing control purposes on a national scale,” said Hixson. “This generates a roadblock in accomplishing the FCC’s recent VoIP order, as the use of routing codes is critical for nomadic and nonlocal area-code subscribers in E-911 service.”
NENA’s request was made as the FCC began accepting comments on expansions to its VoIP E-911 rules, and as a VoIP operator challenged the commission’s E-911 rules in federal appeals court.
Nuvio Corp., which has about 10,000 customers, singled out the efforts of the wireless industry to deploy E-911, noting it has taken years-not the 120 days now mandated for VoIP providers by the FCC.
“The 120-day requirement imposed by the FCC is arbitrary and capricious and without support in the record. In fact, the record clearly shows that wireless companies have been given decades to implement this type of 911 service and are still far from completion,” said Jason Talley, president and chief executive officer of Nuvio.
Nuvio asked the U.S. Court of Appeals for the District of Columbia Circuit to decide the case by Nov. 7 so it will have the necessary time before the Nov. 28 deadline to notify its customers that they are being shut off due to the lack of E-911 capability.
In its comments, CTIA urged the FCC to place any future location requirements on VoIP service providers, not the network operators that may facilitate the calls.
“The nature of the automatic location technology challenge in the VoIP environment further underscores that any E-911 obligation should rest with the provider of such services regardless of the type of network (e.g., wireline, wireless) over which the service is offered,” said CTIA. “It is precisely the nomadic capability of the interconnected VoIP provider’s service offering, not the wireless or wireline transport used in its delivery, that creates the technological challenges in automatically generating location information for the 911 caller and for the PSAP use of that data.”
