I have been watching with great interest the discussions concerning 911 legislation in various states.  While I normally don’t respond to messages on this list, I feel that the topic warrants some serious discussion.  Nuvio is a wholesale VoIP provider and we currently have local numbers in around 4500 cities across the US.  As such, we are a fairly high profile target for states (since we serve all but 2)  While we are starting to deploy some limited E-911 solutions across some of markets (approximately 1/3) the issue of VoIP and legislation is one that we, and personally myself, tackle constantly.  We are a heavy participant in the FCC proceedings as well as active in legislative lobbying at the federal level.  We also spend a fair amount of time dealing with individual states and their attempts to regulate VoIP.  While I agree with previous posts that they may have in fact been preempted by Federal law, this will require a significant court challenge to enforce.  The ensuing time delay in this challenge may seriously harm smaller providers in this marketplace that are not able to endure lawsuits.

 

That being said, I feel that the best course of action is significant involvement and education at any and all levels of government.  Most legislators do not understand the many different flavors of VoIP, the concept of nomadic vs static service and the technological impossibilities of automated address lookup in today’s environment.  Any VoIP provider, large or small should be extremely concerned with any attempt to mandate VoIP 911 access.  The mere fact that most VoIP providers can be used in any locale in a state would mandate interconnection with every PSAP in a state that requires 911 access (like the proposed legislation in KS and IL).  This is further complicated by the fact that most VoIP providers are not certificated CLECs and have no or limited rights of interconnection.

 

To this end, Nuvio has made a significant investment in legal and lobbying resources to try to successful implement the “right” type of regulation.  Regulation will be forthcoming on this and other social issues, it is just a question of if it comes from the federal level or 50 different state jurisdictions.  I for one support a federal regime and believe the FCC is much more able to draft reasonable and technically feasible regulations.

 

As with anything, a solid unified message is important.  We have begun to put together a coalition of VoIP providers and other interested parties to provide a forceful message to the various regulatory bodies.  I would invite any interested parties to contact me off list if they wish to join us in this effort.  We are not looking for financial contributions, just assistance to battle the engrained lobbying positions of the Bells and others.  Hopefully this will allow those providers that do not wish to invest the capital and resources that we have in this fight to have a voice and help guide the proper regulation.

 

 

 

Jason P. Talley

Chief Executive Officer

NUVIO CORPORATION

Phone: 816-444-4422 ext. 6711

Fax: 816-333-5915

http://www.nuvio.com

[EMAIL PROTECTED]

 

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