Title

A Model for Emergency Service of VoIP through Certification and Labeling

Abstract

Voice over Internet Protocol (VoIP) will transform many aspects of traditional telephony service, including the technology, the business models, and the regulatory constructs that govern such service. Perhaps not unexpectedly, this transformation is generating a host of technical, business, social, and policy problems. In attempting to respond to these problems, the Federal Communications Commission (FCC) could mandate obligations or specific solutions to VoIP policy issues; however, it is instead looking first to industry initiatives focused on the key functionality that users have come to expect of telecommunications services. High among this list of desired functionality is user access to emergency services for purposes of summoning fire, medical, and law enforcement agencies. Such services were traditionally required to be implemented (and subsequently were implemented) through state and federal regulations.

An emergency service capability is a critical social concern, making it particularly important for the industry to propose viable solutions for promoting VoIP emergency services before regulators are compelled to mandate a solution. Reproducing emergency services in the VoIP space has proven to be a considerable task, mainly due to the wide and diverse variety of VoIP implementations and implementers. While technical and business communities have, in fact, made considerable progress in this area, significant uncertainty and deployment problems still exist.

The question we ask is this: Can an industry-based certification and labeling process credibly address social and policy expectations regarding emergency services and VoIP, thus avoiding the need for government regulation at this critical time? We hypothesize that the answer is “yes.” In answering this question, we developed a model for VoIP emergency service compliance through industry certification and device labeling. This model is intended to support a wide range of emergency service implementations while providing users with sufficient verification that the service will operate as anticipated. To this end, we first examine possible technical implementations for VoIP emergency services. Next, we summarize the theory of certification as self-regulation and examine several relevant examples. Finally, we synthesize a specific model for certification of VoIP emergency services. We believe that the model we describe provides both short-term and long-term opportunities. In the short term, an industry-driven effort to solve the current problem of VoIP emergency services, if properly structured and overseen as we suggest, should be both effective and efficient. In the long term, such a process can serve as a self-regulatory model that can be applied to social policy goals in the telecommunications industry, making it an important tool to have as the industry becomes increasingly diverse and heterogeneous.

Disciplines

Administrative Law | Communications Law | Comparative and Foreign Law | Computer Law | Consumer Protection Law | Economics | Energy and Utilities Law | Internet Law | Science and Technology Law

Date of this Version

May 2005