VON Europe Comments on DBCDEs IPND discussion paper

Comments on DBCDEs IPND discussion paper

by VON Europe, December 2011 Preliminary Remarks
The Voice on the Net Coalition Europe (VON) welcomes the opportunity to comment on DBCDEs IPND discussion paper (hereafter the Consultation). VON would like to stress that is important to distinguish between fixed and nomadic VoIP, where the first is most often part of a broadband Internet package and thus linked to a fixed internet connection, while the latter can be used in any given location, as long as Internet access is available. Moreover, VON considers it of utmost importance to ensure that any measures should be consistent with the state and widespread use of certain technologies and be associated with and based on the principles of technological and commercial feasibility. More details can be found in VONs responses below.

Detailed Responses
25) What role should the IPND have in delivering dynamic location information to IPND users? How could dynamic VoIP location information be delivered?

VON would like to stress that it is important to distinguish between fixed and nomadic Voice over IP (VoIP), where the first is most often part of a broadband Internet package and thus linked to a fixed internet connection, while the latter can be used in any given location, as long as Internet access is available.1 2 In practice all devices with Internet access have the capabilities to make and / or receive voice communications. Communication anytime, anywhere as long as there is a broadband connection.

See Moore, L. K. (2008). CRS Report for Congress. An Emergency Communications Safety Net: Integrating 911 and Other Services [RL32939]. Washington: CRS (Congressional Research Service). p. 10. Retrieved at, http://assets.opencrs.com/rpts/RL32939_20080825.pdf. 2 See Analysys Mason. (2011). Report for Ofcom Assessment of VoIP location capabilities to support emergency services. p. 6. Retrieved at, http://stakeholders.ofcom.org.uk/binaries/research/telecoms-research/emergency-voip-location.pdf.

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VON Europe Comments on DBCDEs IPND discussion paper

In other words, there is no longer a fixed relationship between the calling line identity (CLI) of the caller and their physical location, unlike in the case of traditional landline services.3 The figure below exemplifies that services, content and applications running over the networks, such as VoIP in this example, are at the mercy of the companies controlling the access network infrastructure.

Figure 1: Comparison of VoIP and conventional landline service delivery models (Source: Ofcom, UK NRA / Analysys Mason )
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VON considers it important in this transition to an all-IP world as not to create new expectations that non-traditional communication tools, such as a number of Voice over IP (VoIP) applications and services, act as a replacement for traditional phone services and can be relied upon to access emergency services. In this context, VON believes that it is premature to expand the emergency services access obligations to require automatic location information, be it from the end-users themselves, from their devices, or from the access network itself, especially for VoIP services and applications that do not present themselves as telephony replacements. VON would like to point out that the provision of caller location information for a network independent VoIP service or application provider and especially in case of nomadic use is more difficult than for a PSTN service provider (or a Voice over Broadband provider that supplies both the network and the voice service) since there is no linkage between the callers location and the underlying physical network. Moreover, VoIP services or applications in general do not have an inherent location function, but are rather depend on other sources for location information, including: static or dynamic IP addresses,

3 4

See Analysys Mason. (2011). Ibid. p. 3. See Analysys Mason. (2011). Ibid. p. 7.

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VON Europe Comments on DBCDEs IPND discussion paper

unaffiliated network access providers, third party location solutions providers or platform location APIs. But at the time being, these sources of location information are not well developed and face a number of challenges, namely: Existing 802.11 standards for enabling automatic location have significant practical limitations as in requiring upgrading (or even replacing) tens of millions of Wi-Fi access points as well as hundreds of millions of existing Wi-Fi enabled handsets and other devices that would also require the updated hardware and chipsets. Calculating location based on Wi-Fi signal Time of Arrival (TOA) technologies or measuring signal strength has significant limitations and challenges, in particular in indoor environments. Commercially available location based services are not sufficient to support emergency location. VON endorses the ACMAs preliminary conclusion in a Consultation Paper earlier in 2011, which stated that a single integrated model for acquiring and delivering location information that is independent of the particular network on which an emergency call originates, and is capable of handling a range of different media as part of the call, may consequently be a logical progression.5 At the same time, VON considers that the efforts should be concentrated on managing consumers expectations and on creating an environment wherein interested stakeholders can work together on solutions that will stand the test of time. Such solution will notably need to support communications that use both Internet names and addresses and telephone numbers. It will also need to address the immediate technological and operational hurdles preventing a move towards a Next Generation 9-1-1 / 0-0-0, interoperable with IP-enabled products, services, applications and devices. However, such an integrated long term approach is not expected in the near future. Therefore, VON considers it premature to issue specific rules at this point in time for network independent service providers. It is interesting to note in that context that the Canadian regulator CRTC reached a similar conclusion as, in looking at the benefits vs. the costs of mandating location capabilities on nomadic 911, it has decided that such a mandate is not justified.6

See ACMA. (2011, January). Numbering: Customer Location Information and Numbering Data [Consultation Paper 2]. p. 43-44. Retrieved at, http://www.acma.gov.au/webwr/_assets/main/lib312038/ifc22011_customer_location_info_and_numbering_data-paper_numbering-2.pdf. 6 See CRTC. (2010). Viability of Proposals for the Provision of E9-1-1 service for Nomadic and Fixed/Non-Native VoIP Subscribers [Telecom Decision CRTC 2010-387]. See Paragraphs 12 and 41. Retrieved at, http://www.crtc.gc.ca/eng/archive/2010/2010-387.pdf.

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VON Europe Comments on DBCDEs IPND discussion paper

It should also be remarked that VoIP 9-1-1 calls are still a marginal phenomenon. In the UK, for example, BT estimates that only 0.45% of the calls originate from a VoIP end-point, which reflects the use of VoIP as a secondary line and also a possible reluctance to use VoIP connections for emergency service calls.7 Imposing additional requirements in the short term on network independent VoIP service providers, especially when their service or application includes a nomadic component, may harm public safety, stifle innovation, stall competition, and limit access to innovative and evolving communication options. The OECD has expressed a similar concern, after seeing what happened to the nomadic VoIP market in the United States, stating that regulators should always consider current technical constraints and while measures should aim to guarantee the safety of users, they should not constitute an unfair burden for providers, and stifle the evolution and development of VoIP.8 Furthermore, because VoIP services are global and the market for IP communications continues to develop, we believe that proscriptive rules ultimately could cause more harm than good for all consumers and create unhelpful precedents for actions in other countries. In the meantime, public resources should be used to educate consumers about the appropriate services and devices from which consumers can expect to make emergency service calls, while at the same time setting appropriate consumer expectations, e.g. the limits of network independent VoIPs location capabilities. These efforts should then resolve the current misalignment between consumers expectations and feasibility and thus reinforce rather than confuse consumers expectation on the providers delivering access to emergency services. If alternative interim approaches other than the existing model would be considered and if in the near term measures for the delivery of real time location information to emergency service organisations would be adopted, it is of utmost importance to ensure that any measures should be consistent with the state and widespread use of certain technologies and be associated with and based on the principles of technological and commercial feasibility. ***

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See Analysys Mason. (2011). Ibid. p. 10. See OECD. (2008). Convergence and Next Generation Networks [DSTI/ICCP/CISP(2007)2/FINAL]. OECD: Paris. p. 40. Retrieved at, http://www.oecd.org/officialdocuments/publicdisplaydocumentpdf/?cote=DSTI/ICCP/CISP%282007%292/ FINAL.

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VON Europe Comments on DBCDEs IPND discussion paper

We thank you in advance for taking consideration of these views. Feel free to contact Herman Rucic, VON Europe, by phone (+32 (0)478 966701) or email (hrucic@voneurope.eu) should you need further information. * * * About the VON Coalition Europe The Voice on the Net (VON) Coalition Europe was launched in December 2007 by leading Internet communications and technology companies, on the cutting edge to create an authoritative voice for the Internet-enabled communications industry. Its current members are iBasis, Google, Microsoft, Skype, Viber and Voxbone. The VON Coalition Europe notably focuses on educating and informing policymakers in the European Union and abroad in order to promote responsible government policies that enable innovation and the many benefits that Internet voice innovations can deliver.

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