Pulver.com Blasts FCC E911 Order (News Release)

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Leading Industry Thought Leader Urges FCC to Ensure America’s Role as the
World Leader in Innovation, Communications and the Internet

MELVILLE, New York, May 19 /PRNewswire/ — The following quotes may be
attributed to Jeff Pulver, CEO of pulver.com in response to the FCC’s adoption
of an order imposing E911 obligations on VoIP providers within 120 days:

The FCC Order is, no doubt, motivated by the most noble of goals —
reliable emergency response systems for all Americans. No one wants, or is
pushing harder to implement these services, more than the VoIP industry
itself. Most PSTN-connected VoIP providers currently provision at least basic
911 emergency services, and typically provision E911 for fixed locations. If
the FCC Order, in fact, compels VoIP providers to offer technologically
impossible enhanced 911 obligations within 120 days of the Order’s effective
date, I fear the Order could put more Americans in harms way by denying
consumers access to useful VoIP services and, in the process, could have
detrimental consequences on the emerging IP-based communications industry, at
least the smaller VoIP providers who cannot feasibly provide a nationwide E911
service within 120 days.


The FCC had a golden opportunity to take one positive steps to promote IP-
based communications. The FCC could have prohibited “port blocking” and
compelled direct access to the ILEC-controlled emergency response
infrastructure. Instead, the FCC chose to regulate the previously
unregulated, and declined to regulate those that it has obvious authority to
regulate — the traditional telecom carriers. As it stands, unaffiliated VoIP
providers are left to the mercy or goodwill of their retail rivals — the
telecom carriers that control access to the emergency response network. The
FCC has given lip-service to its desire to prohibit port blocking and has been
looking for a vehicle to do so. A proceeding fell into its lap, and the FCC
abdicated its responsibility on this issue.

IP technology could allow for functions far beyond the capabilities of
traditional communications networks, but it requires farsighted regulators to
look at the technology with a fresh eye and a commitment not to stifle the
potential and allow innovators to experiment and push the limits of IP
technology. Today, the FCC caved to the shortsighted vision and sacrificed
our long-term emergency response capabilities and America’s role as a leader
in communications, the Internet and innovation.
I, by no means, intend to belittle the noble goals behind a ubiquitous
E911 solution, just the method by which the regulators intend to drive us
there. I am convinced that IP technology will vastly improve emergency
response capabilities. We all want the best possible emergency response
capabilities to become available to all Americans — all the world — as soon
as possible. I, however, do not want to see E911 used as an immediate tool to
bring down the emerging industry, particularly the most vulnerable start-ups
without the deep-pockets, resources, and political connections.

Extending immediate E911 obligations on the smallest, most vulnerable, but
most innovative IP-based communications providers does no one any good (except
for providing a quick political sound bite). In the end, such actions might
mean that no one will ever see the emergency response capabilities that IP-
based communications working cooperatively with NENA could have produced.

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What seems most bizarre to me is that the regulators don’t even seem
willing to give the unaffiliated VoIP providers the minimum set of tools
necessary to accomplish their objective for a guaranteed nationwide E911
network that would allow anyone, anywhere to pick up any device, dial 911 and
have an emergency responder find that caller. If regulators tell the industry
to provide nationwide E911 for nomadic VoIP services, without simultaneously
compelling fair access by unaffiliated VoIP providers to selective routers and
prohibiting port blocking, how can they expect us to accomplish their mission?
Make excessive demands on the never-before-regulated and most-vulnerable new
start-ups, but don’t dare impose any access obligation on the traditionally
regulated entities, the only ones with the essential infrastructure? I don’t
get it.

It makes no sense to stifle the nomadic capability and essentially turn
every IP-based communications service into a fixed line, because the added
nomadic capability of an IP-based service does not avail itself of an
immediate, ubiquitous, localized emergency response solution. Government will
have essentially outlawed a valuable service without having evaluated whether
having extra communications wherever there is an Internet connection could
actually increase the potential that someone’s life could be saved in an

Unaffiliated VoIP providers, even if they had the time, staff and economic
resources to work towards a nationwide solution would be at the mercy of
carriers with whom the VoIP provider would have to partner in order to
establish a nationwide E911 service. The bottom line is that a nationwide
solution does not exist and will not exist in 120 days. If nomadic VoIP
services can operate anywhere there is a broadband connection, it is
impossible for a nomadic VoIP service provider to be in compliance with our
current understanding of the FCC’s likely rule.

VoIP, by its very nature, should empower a user to take her service
anywhere without having to check with the VoIP provider to verify that the
particular remote location has an arrangement with the VoIP provider. It is
one thing to compel a primary fixed-line provider, be it VoIP or traditional
telephony, to provide E911 capabilities, but what logic would be served from
turning off the nomadic capability of IP technology simply because the user
cannot access a local emergency response system when she attaches her computer
with a softphone program or other IP phone to a broadband connection at a
hotel or other remote location? Isn’t it possible that a person at a
Starbucks who witnesses an armed robbery and shooting might be able to save a
life by being able to either dial the police or dial basic 911 using her
nomadic VoIP solution rather than preventing any calls because there isn’t an
E911 capability?

Instead of focusing on the US marketplace, the voice over broadband
entrepreneurs, may instead decide to focus their business activities in
countries that have a more forward looking IP-based communications strategy.
Then again, the pending FCC rulemaking may finally be the shot in the arm
the VoIP entrepreneurs need to come forward with communication services that
are not using VoIP as simple replacement or substitute services, but rather
use IP technology to launch new communication services and applications —
something much truer to the vision of what an IP-enabled platform promises and
not just copycat products or services.

Admittedly, the limited communications network we call the PSTN controls
virtually every communications consumer out there. There was once a time when
the stagecoach controlled most of the transcontinental traffic. Some day,
perhaps now even sooner than some anticipated, the wireline PSTN will be
relegated to be little more than a minor, single-lane off-ramp on the IP-based
network of networks.

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Pulver.com Blasts FCC E911 Order (News Release)

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