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North American Network Operators Group Date Prev | Date Next | Date Index | Thread Index | Author Index | Historical Re: More on Vonage service disruptions...
On Wed, Mar 02, 2005 at 09:46:05AM -0600, Church, Chuck wrote: > > Another thing for an ISP considering blocking VoIP is the fact that > you're cutting off people's access to 911. That alone has got to have > some tough legal ramifications. I can tell you that if my ISP started > blocking my Vonage, my next cell phone call would be my attorney... Why? Do you have a binding legal agreement with your ISP that requires them to pass all traffic? Do you really think you can make a persuasive case that you have an implicit agreement to that effect? (Note that I am not expressing an opinion about whether you _should_ or _might like to_ have such an agreement, just my skepticism that you actually _do_ have such an agreement, and can enforce it) The 911 issue is a tremendous red herring. In fact, it's more of a red halibut, or perhaps a red whale. Vonage fought tooth-and-nail to *not* be considered a local exchange carrier precisely *so that* they could avoid the quality of service requirements associated with 911 service. One of their major arguments in that dispute was that they provided a service accessible by dialing 911 that was "like" real 911 service but that was "not actually 911 service". As I and others noted at the time, that very much violates the principle of least surprise, and is quite possibly more dangerous than not providing any 911 service at all: in New York City, for example, the number to which Vonage sends 911 calls is not equipped to dispatch emergency services and often advises callers to "hang up and dial 911": this _decreases_ public safety by causing people to waste time instead of dealing with emergencies in some constructive way. But Vonage persisted nonethess in insisting that they should not be held to real 911 service standards, and they prevailed, basically by convincing a compliant federal regulatory body with little or no understanding of the underlying technical and human-factors issues to force the state regulators to see it Vonage's way. To turn around now and use 911 reliability (of their service that is "like 911 but not 911" and thus should not _have_ any reliability standards enforced upon it) as a reason why other carriers should be enjoined from filtering Vonage's packets is not just wrong, it's absurd. Of course, like much of Vonage's other rhetoric, it will probably be effective. Ultimately, Vonage will succeed in the marketplace and, in the process of controlling its own costs, manage to wipe away almost all of the traditional regime of regulation of service quality, telco accountability, etc. even in realms like contact to emergency service in which the public good is generally considered to in fact be well served by those regulations. We will have cheaper voice telephone service when all is said and done but will we, eventually, be forced to turn around, after Vonage uses cheaper costs from differential regulation to wipe out all the old wireline carriers, to painfully reinstate a large part of the old regulatory regime to ensure that telecom services that we believe essential to the public good are not (or do not remain) wiped out as well? Thor
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