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To the most honorable Chairman Martin |
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Written by Ken DiPietro
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Thursday, 19 May 2005 |
On Monday morning I read the announcement of the Open Commission
Hearing scheduled to discuss the Universal Service Fund issue and E911.
(My initial comments can be found here)
Chairman
Martin, I want you to know that I have some pretty high expectations
for you, expectations that are probably more based on what I hope you
will accomplish rather than what your past voting history or published
views might indicate. What I do know is that you are on the younger
side, very technically savvy and an extremely sharp gentleman.
Whenever there is a transition of leadership there is a necessary
pause before we can see what direction the new leadership will
implement. One policy that I am hopeful will be retained is the
openness the FCC has fostered in recent years. If there has been
anything that has demonstrated to the American public and the small
businessperson that we have a real voice in the crafting of
regulations, this is certainly it.
To that end, I would like to
take this opportunity to explain my feeling on the E911 issue. I have
already detailed my opinion on the Universal Service Fund so I am going
to leave that subject alone and instead focus on the E911 issue. It is
my understanding that the ILECs are in almost every case the companies
who are be terminating calls to the E911 service. I would suggest that
this would indicate that the onus of connecting the VoIP providers
should squarely rest on their shoulders.
According to this article in Reuters the FCC is going to require VoIP companies to provide E911 service within the next 120 days.
“Under
pressure from state law-enforcement agencies and Congress, the Federal
Communications Commission plans to require VoIP companies to provide
911 services to customers within 120 days of its order being published,
two officials familiar with the FCC plan said.”
Here
is how I look at the situation, we need to let the ILECs know that we
believe this responsibility should be shouldered by them – period. That
is exactly what the ILECs are supposed to be doing – minding the core
of the telephone infrastructure.
Without knowing the actual
mechanism the FCC will be proposing it is difficult for anyone to add
comment at this time but there is one point I would like to interject,
if I may. Over the last several years I believe there is a mountain of
evidence that the corporate mindset of the ILECs is one of making it
very difficult for anyone the ILECs believe to be their competition to
interact with them.
Now, as a alternative suggestion, it would
seem trivial to require the manufacturers of telephones to include a
“panic button” built right into their equipment. In today's advanced
world of telecommunications it should be a very easy feature to set up
on any telephone in the United States.
This is how I would
envision the system working. A consumer purchases a new E911 ready
telephone and when they install it the phone dials into the POTS
infrastructure and receives the necessary information to automatically
configure the E911 button. Regardless of what kind of connectivity the
customer has it should be very easy for the POTS system to coordinate
with the VoIP provider and the connectivity supplier to get the
physical location from the hardware installed (cable or DSL modem MAC
address) and supply the necessary information to the E911 system.
I
do understand that this would lead to a number of “accidental”
activations but from what I understand the amount of calls to the 911
service that are not emergency related is astronomical anyway.
Researchers
estimate that 60 to 90 percent of 911 calls are not emergency calls.
According to a study sponsored by the National Institute of Justice,
non-emergency 311 call systems can greatly reduce the 911 burdens.
Let
me say this clearly, Chairman Martin, I believe you are a man who has
taken on an incredibly difficult job, one that also affords you a
fantastic opportunity to move this country ahead in this most critical
area. From what I can discern you are a man of integrity along with the
experience and capability to see through all of the hype. We (I mean this entire country)
needs you to move us forward quickly, in a bold new direction. I do
expect that the lobbyists needs to be given access, listened to but
also filtered with the aim of only allowing what is good for our entire
nation – not just what a largely obsolete network provider needs to
continue to deliver miserable and outdated service.
Chairman
Martin, sir, if I may, this is what I would like to suggest. We need to
provide the ILECs with relief from having to service wide areas of this
country that will never be anything but a money losing proposition for
them. In order to do this, we need to make it not only possible but easy
for alternative connectivity companies to provide essential services in
these areas. This is without doubt a winning mechanism for not only the
ILEC but more importantly for the American consumer.
It is time
for you to chart a new course for our communications infrastructure. We
must do something different from what has been our course until now
because it is readily apparent that we have fallen so far behind the
rest of the industrialized world that this is a source of national
disgrace. In order for us to move ahead and reclaim a position that
approaches the top of the list we will need to to look at any
reasonable method we can reliably employ to deliver not only broadband
but VoIP as a REAL substitute for POTs service.
I would also
like to go one step farther, at this time I can tell you that the FCC
is now under more scrutiny by the public than at any time I can
remember in my life. We need to look at how the FCC can remain relevant
in the average American's life, something that I have seen firsthand
with the FCC.
What I most fear is that if the perception by
many that the FCC is pretty much owned by the ILECs. I need you to know
that many of us believe the ILECs have completely failed in delivering
the broadband connectivity the American public sorely needs. Instead of
supporting this culture it is time to force the ILECs to stand on their
own feet.
To that end, I ask that you direct the FCC in such a
way as to discontinue the Universal Service Fund and require the ILECS
to make it possible for anyone who wishes to get access to the E911
service and connectivity to their networks at very reasonable prices.
Thank you for your time.
Respectfully,
Ken DiPietro
New-ISP
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