The FCC's E911 order was supposed to be complied with by November 28. The idea was that all "interconnected VoIP" customers would have acknowledged by then the limitations on any E911 service provided by their vendors, and would have received stickers repeating this warning. VoIP customers who didn't have E911 service were to be cut off. (None of this ever happened to wireless or wireline companies that were having trouble with 911 services -- no acknowledgements, no limitations on marketing, and certainly no requirement to terminate service.)
The Commission has relented, slightly. They'll forbear from enforcing the acknowledgement requirement, as long as they keep getting detailed reports from the VoIP providers. And:
Although we do not require providers that have not achieved full 911 compliance by November 28, 2005, to discontinue the provision of interconnected VoIP service to any existing customers, we do expect that such providers will discontinue marketing VoIP service, and accepting new customers for their service, in all areas where they are not transmitting 911 calls to the appropriate PSAP in full compliance with the Commission’s rules.
That's remarkable. Stop selling these wildly successful services, you industry, until you've plugged into our legacy emergency system. Okay, so you don't have authority to plug into the system. Go work with a third party! Okay, so no third parties have nationwide nomadic 911 capabilities (and when one emerges, it will have a captive market) -- just do your best, and we'll be watching. In fact, we think you should do just what Verizon and AT&T did when they did their mergers. They had some great plans for compliance, and it's only coincidental that those plans were filed just before we allowed the mergers to go through.
We think (this is still the voice of the FCC, although parody is difficult in the blog format) that Verizon had an "innovative compliance plan" for nomadic 911. Here are the details:
By November 28, Verizon expects to have a capability to detect when a customer’s VoiceWing telephone adapter is disconnected from the network. If we detect that the customer’s adapter has been disconnected, we will suspend the customer’s service, with the exception of 911 calls and calls to customer service. At the same time, we will send the customer an e-mail and post a message to the customer’s Personal Account Manager asking the customer to confirm his or her existing Registered Location, or register a new location.
While in suspend status, if the customer attempts to make any calls, other than 911 calls or calls to customer service, before he or she confirms or registers a new location, Verizon will intercept the call and play an announcement that will inform the customer of the service suspension and transfer the customer to a customer service representative for assistance. If the customer confirms to the service representative that the customer’s Registered Location has not changed, full service will be restored by Verizon. If the customer indicates that he or she has moved from the existing Registered Location, service will remain suspended unless and until the customer registers a new address in an area where Verizon can provide 911 service. If the customer fails to choose either option (for example by hanging up), service will remain suspended . . . As a result, the customer will be required to register a new address when the service is used nomadically.
Ta-daah! Very innovative. And the FCC is strongly encouraging VoIP providers to mimic the AT&T/Verizon promises -- here's the threat: "The Bureau applauds the steps undertaken by AT&T, MCI and Verizon and strongly encourages other providers to adopt similar measures. The Bureau will carefully review a provider’s implementation of steps such as these in deciding whether and how to take enforcement action."
Someone publicly suggested at the Pulver conference the other day that the E911 rules had been written by third-party providers of E911 compliance technology. Digging, digging. At any rate, this shows what regulatory mischief can be done at key moments in a company's history -- such as when a merger needs to close.