The VoIP E911 Problem - Solution Needed

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The Calgary Herald printed an article today commenting on the events that may have contributed to the death of a Calgary toddler. The article calls for regulators to mandate that VoIP providers have direct connections to 911 services. I agree.

As I have pointed out many times here previously, having 911 calls redirected to call centre has the potential of compromising the efficacy of the response. This is especially true when one considers that the person accepting the call almost certainly does not have the experience and training of a 911 operator.

The article points out that Canadian VoIP service providers opposed regulations that would have forced them to have direct connections to 911 call centres. I’m not convinced that’s entirely correct. If memory serves me (someone please correct me if I’m wrong), 911 centres themselves were opposed to direct connections from VoIP providers that could not guarantee that the provided address of the 911 caller was accurate.

Also, while I agree that VoIP based 911 calls should go directly to a 911 dispatch centre, it may not have made any difference in this case. Direct connection or not, the address in the database was wrong. Perhaps a 911 operator would have handled the situation better, perhaps not.

The fact is that with nomadic VoIP services, there is no fool proof way (that I know of) of ensuring that the location information associated with a 911 call will always be correct. I’ve given this subject a lot of thought over the years because I have always been troubled by the potential consequences. There are ways of addressing the problem, at least partly, but none of them are perfect or for that matter, practical.

What follows are various methods of associating a caller with a location:

Physical Connection

The telephony device is bound to a physical location. That’s the situation with a POTS line; the regular telephone service from your telephone company. The telephone is connected to a pair of wires which the telephone company can accurately associate with an address and the address never changes. In some cases a VoIP provider can use the same method but only if they control the entire infrastructure associated with the service which is the case with most cable companies.

Heartbeat

A VoIP provider can monitor the end device and detect a possible change in location. If the device goes out of service and then comes back into service with a different IP address, then it may indicate that the device has been moved. The key word is “may” since there are many situations where this could occur even if the device had not been moved. Still, the service provider could configure the service so that under this circumstance, the telephony user must confirm their address before the service is restored. There are many problems with this approach including the scenario where a caller connects a previously disconnected device and attempts to make a 911 call. Insisting that the caller first confirm the address before the telephony service is restored is not sensible in this circumstance!

Global Positioning Systems

Imbed GPS receivers in the telephony devices. Besides the fact that other components would be required to associate the GPS coordinates with physical addresses this approach is not practical for at least two reasons. The first is the cost associated with the GPS receivers. One can argue that cost should not be a factor when it comes to public safety but the fact remains that VoIP services will not exist if the economics don’t make sense. The second problem with this approach is that GPS receivers simply don’t work very well indoors. In fact in many situations they will be completely non functional.

Conclusion

The death of this child is tragic. The fact that a shortcoming of VoIP service may have played a role is also very troubling. It’s not the first event of its kind and sadly, it likely won’t be the last. However, the answer is not to shut down VoIP service providers - although I suspect the Telcos would be in favour of that option!

I’m sure a practical solution will eventually emerge. In the meantime if you are VoIP customer ensure that the address information on file with your provider is accurate. Do it now!

Note:

The 911 challenges discussed above relate to nomadic and residential VoIP or Internet Telephony services. When it comes to IP Telephony services for business, all of the E911 concerns can, and are routinely addressed satisfactorily.


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4 Comments

Anonymous said:

Rick,

I agree with 99% of your article, and kudos for raising the public concern. The part that I don't agree with is your last note, "The 911 challenges discussed above relate to nomadic and residential VoIP or Internet Telephony services. When it comes to IP Telephony services for business, all of the E911 concerns can, and are routinely addressed satisfactorily."

Although it is entirely true that just about all of the mobility concerns with business IP Telephony CAN be addressed, the fact that they ARE addressed is far from correct. Not only does nomadic IP Telephony challenge most business Multi Line Telephone System (MLTS) operators, traditional telephony is also not being addressed by managers as well.

Businesses quite often forget about this crucial part of the implementation of any MLTS communications system, and improper Caller ID (the trigger for proper E911 resolution) is commonly sent on 9-1-1 calls.

The fact that only 14 states in the US actually have any laws on the books dealing with MLTS E911 requirements is a shocking testimony of the failure of legislation to recognize this tragedy waiting to happen. It is only when someone looses a life is the problem even discussed, and that is unfortunately too late for many. Families are left with out fathers and mothers from a simple configuration mistake or lack of planning.

in the US it is estimated that over 60,000,000 people spend their workday being serviced by an MLTS. I would estimate that 70% of those systems do not have E911 properly or efficiently provisioned. It's time for government to wake up and take notice before more lives are lost.

Mark Fletcher said:

Rick-

I agree 100% with the previous comments. MLTS E911 is a problem in many environments, however it is one that can be solved. Education is the key here. Most folks do not understand how E911 works, and therefore have no idea what that they even should or can do anything to improve their situation.

NENA (the National Emergency Number Association) has just completed the final drafts of new model legislation as well as a Technical Information Document outlining what can be done in different environments as well as some recommended best practices. These documents will go out for public review shortly, and once adopted will be available to all.

The comments made about only 14 states in the US having legislation on the books is a sad, but true fact. NENA published a model legislation document back in 2000, however there have been tremendous changes in technical capabilities over the past 8 years. Although VoIP does introduce new challenges, it is one of location discovery, very much the same issues you highlighted in your article. It is important to remember it is not the technology of VoIP that makes E911 problematic, it is the ability for a user to move themselves without administrative intervention.

The problem herein is that the FCC in the US delegated this down to the state level, and there is no over arching control point for uniform rules, regulations and requirements. Many legal experts will argue this may even be an OSHA issue, and that can carry stiff penalties in itself.

In any case, businesses need to take steps to protect themselves, and their employees, and the best first step is public education. People do not know the issue exists, or assume that the fix is in place when it is in fact not even addressed. A great podcast that I recorded with Guy Clinch from Avaya for the Voice Report is available to those interested at http://thevoicereport.com/TelecomJunkiesArchive-E911.

This is an excellent overview on the problem at hand, as well as some simple explanations and suggestions of what to do.

MLTS operators need to understand E911, and their risk. Lives are at stake, and ignoring the problem will in no way make it go away. Many of this will be fixed with NextGen E911, but that is a whole other topic for another time.

Mark Fletcher, ENP
Nortel E911 Product Manager
NENA MLTS Technical Committee Chairperson

Thanks for both of your comments on the MLTS aspects of E911.

My final comment in the article was intended to make a distinction between what I commonly refer to as "enterprise class telephony": a professionally designed, configured and installed telephony system in a business environment vs. residential VoIP services.

The note said "all of the E911 concerns can, and are routinely addressed satisfactorily." The keyword is "can". I did not say that they necessarily are.

The important point is that within enterprise class telephony, E911 can be completely addressed. In fact, IP Telephony permits E911 enhancements not possible with traditional technology.

IP Telephony systems can accurately locate and report the location of a 911 caller within an enterprise's limited geographic and administrative boundaries.

How do you handle IP Phones that move outside of those administrative and geographic boundaries? Detect the condition and do not allow the phone to activate.

Bottom line is that when it comes to enterprise telephony, there are no technological barriers limiting full E911 functionality. It is the business owners' ethical responsibility to ensure that the telephony systems are properly installed, configured and maintained. It is the same ethical responsibility that would apply to a building's fire detection and suppression systems.

With respect to residential VoIP services there is no practical technology-based solution to adequately address the nomadic aspects with respect to 911. In the absence of a technology solution the industry leaders, service providers, emergency operators and regulators should bear the ethical responsibility to educate consumers and to remove all processes (like call centres) that can limit the efficacy of 911 call and its response.

Rick McCharles

julie kivell Author Profile Page said:

Thanks Rick - you've provided better info and coverage than most of the media outlets! :-)

I'm guilty of having an old home address on file with my VoIP provider (just fixed it today after 2 years) - - and I tend to agree that it's a matter of public education and awareness. VoIP certainly isn't *grandma's type of phone service*....

There's got to be an easier way for the VoIP provider to stay current with address changes. The geek in me suggests that in the next few years, all phones, regardless of use - wireless or wireline, VoIP or traditional TDM technology could have a GPS chip that could rely on wifi or wireless networks to transfer accurate address information to the e911 operator to validate location......

Cheers,
Jules

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This page contains a single entry by Rick McCharles published on May 4, 2008 5:02 PM.

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