Public-safety answering points, or PSAPs, won a crucial victory in December with the passage of federal legislation to help fund upgrades designed to let PSAPs provide E911 services to calls from mobile phones. But the rapid adoption of so-called nomadic and mobile voice-over-IP offerings has vendors and public-safety officials scrambling for answers to problems that could be much more complex than the challenges faced when wireless E911 emerged.

Once topics of theoretical discussions, the limitations of the legacy 911 system as it relates to VoIP users have become a stark reality — a fact underscored during a Feb. 3 incident in Houston, where a young girl dialed 911 from a VoIP phone to get help for her parents, both of whom had been shot. Instead of reaching a PSAP, the girl heard a message that 911 was not available from the VoIP phone.

Although some VoIP providers offer full-fledged E911 service, most VoIP companies that provide consumers with substantial savings compared with traditional wireline service do not. For these providers, 911 services may be offered separately, may require the user to manually input address information or may not be offered at all.

Even if a VoIP 911 service is offered, emergency calls typically are routed to the PSAP's administrative offices instead of directly to a dispatcher. In addition, 911 services requiring customers to input address information typically are not updated in the Automatic Location Identification (ALI) database in real time, meaning 911 calls made soon after a move could be sent to the wrong PSAP.

Regardless of how many disclaimers a VoIP provider makes when selling its service to customers, the danger is that users will pick up a phone expecting traditional 911 service in an emergency — functionality that may not be available on a VoIP phone, wrote Association of Public-Safety Communications Officials President Greg Ballentine in a Feb. 15 letter to President George W. Bush.

“The public has an expectation that telephone services will provide 911 and Enhanced 911 capability, regardless of whether the telephone operates on the public switched telephone network, wireless networks, or the Internet,” Ballentine stated in the letter. “Yet, at present, there is a very real likelihood that a 911 call from a VoIP telephone will be lost, delayed, or misrouted.”

And the number of incidents such as the one in Houston likely will become more common. Although residential VoIP users still represent just a small fraction of overall phone users, the numbers are expected to increase during the next few years — a sticky situation for a PSAP community still having difficulty providing E911 to the much more mature mobile wireless industry.

“[VoIP is] killing us where we are right now, and it's still relatively new,” Bob Currier, director of PSAP relations for Intrado's government and external affairs department, said during a presentation at APCO's Winter Summit conducted a little more than a month ago in Orlando, Fla.

Ballentine's letter to President Bush was even more blunt.

“Simply stated, if VoIP progresses as is, the public's safety is at risk,” Ballentine wrote.

With this in mind, Ballentine's letter calls for Bush's support as APCO lobbies the FCC for rules that would require VoIP services to include full 911 capabilities. But at least two key factors threaten to undermine such efforts.

First, the FCC has long valued competition in the voice sector. VoIP represents the greatest opportunity for such competition, especially in the wake of new, court-ordered FCC rules that effectively eliminated competitive local exchange carriers, or CLECs, from the consumer voice market.

Led by Chairman Michael Powell, the FCC has called for a “light regulatory touch” on VoIP. Mandating full 911 compliance, as APCO requests, likely would be a prohibitive barrier to many emerging VoIP companies, thereby reducing competition in the voice market. Requiring consumers who have benefited mightily from low-cost VoIP services to return to traditional, higher-priced offerings from incumbent wireline carriers in the name of 911 may not be perceived as serving the public interest.

Second, even if such a rule were passed, enforcing it would be difficult. The notion of requiring VoIP companies to provide full 911 services sounds reasonable, in the current context of a provider/customer relationship. But so-called “asterisk servers” — an increasingly popular open-source PBX that connects to SIP phones — will allow people to make VoIP calls without an agreement with a VoIP service provider, said Rob Smith, director of sales for HBF Group.

“Eventually, a VoIP provider won't be needed,” Smith said. “Now, anybody can be a VoIP provider — every kid in his dorm room is going to do this. … And how are you going to answer these [911] calls? We can't, with the current system.”

A more immediate threat is Skype, a Luxembourg-based VoIP company that reportedly has had its free peer-to-peer VoIP software downloaded 73 million times since August 2003. Now, Skype is offering a prepaid service — called SkypeOut — that lets users dial any number in the world at a fraction of traditional telephony costs.

Most believe the FCC would be hard-pressed to require Skype to provide 911 services — or anything else, for that matter. Skype is not a U.S. company, and it's not a carrier. Regulating a software company like Skype or U.S. VoIP poster child Vonage would open a Pandora's box that could lead to unwanted regulations on other packet-based communications, including instant messaging and e-mail.

Further complicating the VoIP situation is the fact that many forms of the technology exist, each with its own set of circumstances, challenges and voice quality. In terms of 911 functionality, the offerings vary significantly — from wireline telephony-quality 911 to optional solutions to no 911 service at all. One underlying factor seems to be constant trend, said James Cavanagh, global telecom network and security consultant for The Consultant Registry. “For the most part, you get what you pay for,” Cavanagh said.

For instance, the VoIP offerings provided by large cable companies — many of which have 911 experience through CLEC arms — often are on par with most traditional wireline telephony, in terms of 911 functionality, Cavanagh said. However, cable operators' prices typically offer little discount to consumers when compared with traditional telephony offerings.

“The cable companies have done the [911] job right,” Cavanagh said, noting that cable companies dubbed their service “digital voice” to differentiate themselves from other VoIP providers. “Was the cost high? It was massive.”

In addition to the monetary investment, the key reason these cable models work is that the connections are static — the phone works only from a given address, which can be input into the ALI database used by a PSAP. Such static VoIP offerings can be integrated into the existing PSAP infrastructure.

But one of the big selling features of VoIP products such as the ones offered by Vonage or Packet 8 are their portability. Known as “nomadic” VoIP, these services let customers take their phones with them when traveling. The phones will work with any broadband connection, while maintaining the same phone number — regardless of the caller's real location.

After moving, if a customer has not input his new address — or the new address has not been updated in the ALI database — a 911 call will go to the PSAP in the area of the previous address. In this scenario, a Chicago person using a nomadic VoIP phone while vacationing at a timeshare in Miami would dial a Chicago PSAP with a 911 call, despite calling from Miami.

Accommodating full-fledged mobility for VoIP adds another layer of complexity for PSAPs. To date, there has been little traffic in this category, but that's about to change. Last month, Motorola announced that some of its mobile phones will be embedded with Skype software by the end of the year.

A Motorola spokeswoman said the company had not identified which phones would include Skype, but most analysts believe such an offering would be ideal for Motorola's enterprise phone, which allows seamless mobility between cellular and Wi-Fi networks.

“From a strategic standpoint, it's brilliant, absolutely brilliant,” Cavanagh said. “Motorola legitimizes Skype to the telecom world, and Skype legitimizes Motorola to the fringe world.”

It may be good business, but the Skype/Motorola relationship potentially is a major headache for PSAPs still struggling to handle mobile cellular calls and arguably years away from providing E911-like response to VoIP calls.

“I don't know all the details, but it sounds like the worst of both worlds,” said one public-safety official who requested anonymity.

Determining the best solution for VoIP 911 calls is being debated in multiple standards bodies. One thing that seems certain is that PSAPs cannot afford to ignore the problem, morally or financially.

“Is refusal to answer 911 calls from VoIP phones a viable solution?” HBF's Smith asked. “How long will it be before a grieving parent files a class-action lawsuit?”

Every proposal being discussed requires additional money, but finding funding sources could be extremely difficult. Emerging VoIP companies cannot afford such a major expense, and PSAPs also are cash-strapped.

“Local PSAPs will crumble in economic ruin if they must continue to have to provide an ever-widening array of mechanisms of getting caller information into our systems,” Ballentine said in his letter to President Bush. “Similarly, the ever-growing base of voice providers would go broke if they had to interact with each and every PSAP in a unique way that may not be the same 100 miles down the road.”

Some industry officials advocate halting the expensive and time-consuming cycle of trying to retrofit legacy PSAPs to handle new technologies by moving to an IP-based system that can fully take advantage of Moore's Law economics and can be upgraded largely through software downloads.

Such an approach might be most economical for the long term, but it would require significant upfront costs. With Congress still needing to approve the appropriations on its five-year funding plan for Phase II wireless upgrades to PSAPs, the notion of securing money for an even bigger upgrade in the near future “might be a pipe dream,” one Capitol Hill staffer said.

What's it VoIP sound like?

Results of a non-scientific 911 VoIP test conducted at the Georgia Public Safety Training Center

  • VoIP performed better than expected:

    • Transmitted discernable male whisper
    • Transmitted smoke alarm at 15 feet
    • Performed better than expected for gun shots
  • VoIP did not perform as well as wireless

  • With specialized training, 911 call takers should be able to recognize most tested sounds

  • With audio enhancement, many of the VoIP sounds may be usable for evidence “after the fact”

Sources: APCO, The Consultant Registry